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← 64 TC 223 - Computing & Software, Inc. v. Commissioner

Computing & Software, Inc. v. Commissioner’s Empirical Analysis

1975

Citation profile

44
cited by 44 later decisions
October 2016
most recently cited

2 federal appellate ·

How this case has been cited

Cited by 44 later decisions — most recently October 2016 · most notably Ronnen v. Commissioner (1988), IT&S of Iowa, Inc. v. Commissioner (1991)

2 federal appellate ·

14019751980199020002010decided

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 Cohan v. Commissioner · Johnson v. United States · Rogers v. Loether · Cass v. United States · Commissioner v. Ferrer

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

  1. “—an organization that was doing business and earning money; a network of customers and the expectation that their patronage would continue; a staff of employees trained in working with the credit files and dealing with the organization’s customers; an established routine for supplying available credit information and obtaining and recording new data from various sources; and an established routine for recording the fees charged for credit-reporting services and billing the customers. * * * [Computing & Software, Inc. v. Commissioner, supra at 235.]”
    1 later decision quote this exact passage
  2. “While we need not consider this argument, Estate of Dorothy E. Beck , 56 T.C. 297 , 347 (1971) , we think it lacks merit. The essence of the asset acquired by petitioners was the credit information contained in the files, not the files as such, and that information was obviously intangible property. * * * [ 64 T.C. at 238 n. 16 .]”
    1 later decision quote this exact passage · from the majority
  3. “The term 'property' includes intangibles.”
    1 later decision 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.