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← 598 F.2d 1375 - Brittingham v. Commissioner

Brittingham v. Commissioner’s Empirical Analysis

1979

Citation profile

26
cited by 26 later decisions
1
states following
January 2013
most recently cited

1 federal appellate · 1 state decisions

How this case has been cited

Cited by 26 later decisions — most recently January 2013 · most notably Achiro v. Commissioner (1981), Thompson v. Commissioner (1982)

1 federal appellate · 1 state decisions

17019791980199020002010decided

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 Commissioner of Internal Revenue v. Duberstein D Stanton · Local Union No. 12 v. National Labor Relations Board · Illinois ex rel. Kennedy v. Hurley · Louis Weber v. United States · Federal Trade Commission v. Procter & Gamble Co.

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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “controlled directly or indirectly by the same interests,”
    2 later decisions quote this exact passage · from the majority
  2. “includes any kind of control, direct or indirect, whether legally enforceable, and however exercisable or exercised. It is the reality of the control which is decisive, not its form or the mode of its exercise. A presumption of control arises if income or deductions have been arbitrarily shifted. The”
    1 later decision quote this exact passage · from the majority
  3. “an arm's length price (for tangible property such as tile) is the price that an unrelated party would have paid under the same circumstances for the property involved in the controlled sale.”
    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.