Commissioner v. Transport Manufacturing & Equipment Co.’s Empirical Analysis
478 F.2d 731 · 1973
Citation profile
26 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 95 later decisions — most recently April 2020 · most notably Estate of Newhouse v. Commissioner (1990), Foster v. Comm'r (1983)
26 federal appellate · 3 district · 1 state decisions
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 · 26 U.S.C. § 7482
Relies on Welch v. Helvering · Wilmington Trust Co. v. Helvering · Commissioner v. Riss · Riss v. Commissioner · Nat Harrison Assoc., Inc. v. Commissioner
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 95 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(b) Form of answer . The answer shall be drawn so that it will advise the petitioner and the Court fully of the nature of the defense.”
7 later decisions quote this exact passage · from the majority“The basic consideration is whether the taxpayer is surprised and disadvantaged when the Commissioner has failed to plead [the theory in a timely fashion] ....”
6 later decisions quote this exact passage · from the majority“[i]n reviewing Tax Court decisions, we apply the clearly erroneous standard. Findings supported by substantial evidence on the record as a whole which are not against the clear weight of evidence or induced by an erroneous view of the law will not be disturbed on appeal”
2 later decisions 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.