Catron v. Commissioner’s Empirical Analysis
1968
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 45 later decisions — most recently July 1999 · most notably Coors v. Commissioner (1973), Yellow Freight System, Inc. v. United States (1976)
6 federal appellate ·
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
Relies on Evans v. Commissioner · Madison Newspapers, Inc. v. Commissioner · Schuyler Grain Co. v. Commissioner · J. E. Barron Plastics, 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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(5) Storage facilities. If property (other than a building and its structural components) is a storage facility used in fanning such as the cultivation of the soil or the raising of livestock, and if it cannot be reasonably adapted to other uses, it qualifies as ‘other tangible property’ within the meaning of section 48(a)(1) of the Code, regardless of whether it is a temporary or a permanent facility. Typical storage facilities on farms include grain storage bins, corn cribs and silos. These are all to be distinguished from farm buildings which do not qualify as section 38 property, such as barns, stables, poultry houses and warehouses. All of these contain space within which the farmer works and carries on his farming activities and are ineligible for the credit because they fall within the definition of the term ‘building.’ A storage facility, as above illustrated, provides the farmer only storage space but not working space.””
3 later decisions quote this exact passage“(a) Section 38 Property.'— (1) In general. — Except as provided in this subsection, the term “section 38 property” means— (A) tangible personal property, or (B) other tangible property (not including a building and its structural components) but only if such property (i) is used as an integral part of manufacturing, production, or extraction * * *, or (ii) constitutes a research or storage facility used in connection with any of the activities referred to in clause (i). * * *”
2 later decisions quote this exact passage“generally means any structure or edifice enclosing a space within its walls, and usually covered by a roof, the purpose of which is, for example, to provide shelter or housing, or to provide working, office, parking, display, or sales space. The term includes, for example, structures such as apartment houses, factory and office buildings, warehouses, barns, garages, railway or bus stations, and stores. The regulation excludes, however, from the definition of the term”
2 later decisions quote this exact passage
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.