Lufkin Foundry & Machine Co. v. Commissioner’s Empirical Analysis
468 F.2d 805 · 1972
Citation profile
9 federal appellate · 1 district ·
How this case has been cited
Cited by 25 later decisions — most recently November 2020 · most notably Eli Lilly Company v. Commissioner of Internal Revenue (1988), Ross Glove Co. v. Commissioner (1973)
9 federal appellate · 1 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 26 U.S.C. § 482
Relies on Commissioner v. First Security Bank of Utah, N. A. · Young & Rubicam Inc. v. United States · Spicer Theatre, Inc. v. Commissioner of Internal Revenue · American Terrazzo Strip Co. v. Commissioner · Baldwin-Lima-Hamilton Corp. v. United States
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“evidence of transactions between uncontrolled corporations”
3 later decisions quote this exact passage · from the majority“For the purposes of this paragraph, an arm’s length rental charge shall be the amount of rent which was charged, or would have been charged for the use of the same or similar property, during the time it was in use, in independent transactions with or between unrelated parties under similar circumstances considering the period and location of the use, the owner’s investment in the property or rent paid for the property, expenses of maintaining the property, the type of property ■ involved, its condition, and all other relevant facts. .”
2 later decisions quote this exact passage · from the majority“[section 1.482—2(e)(1) (iii)] states that where the standards set out in the regulations indicate that one of the three methods is applicable, the taxpayer may avoid its application only by demonstrating that some other pricing method is clearly more appropriate. Lufkin has not shown that each of the three methods is inapplicable, nor has it shown that a more appropriate method ought to be utilized. [ 468 F. 2d at 808 .]”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.