Kramertown Co. v. Commissioner’s Empirical Analysis
1974
Citation profile
22 federal appellate · 1 state decisions
How this case has been cited
Cited by 40 later decisions — most recently April 2007 · most notably Anderson, Clayton & Co. v. United States (1977), Piggly Wiggly Southern, Inc. v. Commissioner (1986)
22 federal appellate · 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. § 38
Relies on Isbell Enterprises, Inc. v. Citizens Casualty Co. of New York · Watson v. Commissioner · Minot Federal Savings & Loan Ass'n v. United States · Ft. Walton Square, 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(2) The term “structural components” includes such parts of a building as walls, partitions, floors, and ceilings, as well as any permanent coverings therefor such as panelling or tiling; windows and doors; all components (whether in, on, or adjacent to the building) of a central air conditioning or heating system, including motors, compressors, pipes and ducts; plumbing and plumbing fixtures, such as sinks and bathtubs; electric wiring and lighting fixtures; chimneys; stairs, escalators, and elevators, including all components thereof; sprinkler systems; fire escapes; and other components relating to the operation or maintenance of a building. However, the term “structural components” does not include machinery the sole justification for the installation of which is the fact that such machinery is required to meet temperature or humidity requirements which are essential for the operation of other machinery or the processing of materials or foodstuffs.”
2 later decisions quote this exact passage · from the majority“[r]egulations issued pursuant to the express statutory authorization in Section 38(b) are legislative in character and as binding upon a court as a statute if they are (a) within the granted power (b) issued pursuant to proper procedure and (c) reasonable.”
2 later decisions quote this exact passage · from the majority“quality of removability is not the sole determinant of whether a piece of machinery is a structural component.”
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.