Thompson v. Commissioner’s Empirical Analysis
1978
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 30 later decisions — most recently May 2013 · most notably Oakton Distributors, Inc. v. Commissioner (1979), Dumaine Farms v. Commissioner (1980)
3 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
Applies 26 U.S.C. § 7476 (§ 1041 of the Employee Retirement Income Security Act of 1974)
Relies on Aetna Life Ins Co of Hartford Conn v. Haworth · Maryland Casualty Co. v. Pacific Coal & Oil Co. · Golden v. Zwickler · Altvater v. Freeman · Anthony 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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“whether the Commissioner, in making his determination, properly applied the law to the facts presented to him in the request for such determination.”
4 later decisions quote this exact passagee.g. Robert C. Wenzel, James F. Moulthrop and Donald Wilson v. Commissioner of Internal Revenue, and John Hoh, Kenneth Carroll, David Greenhut, Dominic Accetta, Angelo Ferraro, and A.J. Grau, Former Trustees of the Brewery Workers Pension Fund, New York State Teamsters Conference Pension and Retirement Fund, William H. Mosley, Sr., Administrator, John Delguidice, Wayne W. Woodhead, and Anthony J. Dunadee v. Commissioner of Internal Revenue, and John Hoh, Kenneth Carroll, David Greenhut, Dominic Accetta, Angelo Ferraro, and A.J. Grau, Former Trustees of the Brewery Workers Pension Fund, New York State Teamsters Conference Pension and Retirement Fund, William H. Mosley, Sr., Administrator v. Commissioner of Internal Revenue, and John Hoh, Kenneth Carroll, David Greenhut, Dominic Accetta, Angelo Ferraro, and A.J. Grau, Former Trustees of the Brewery Workers Pension Fund · New York State Teamsters Conference Pension & Retirement Fund v. Commissioner“The court is to base its determination upon the reasons provided by the Internal Revenue Service in its notice to the party making the request for a determination, or based upon any new matter which the Service may wish to introduce at the time of the trial. The Tax Court judgment, however, is to be based upon a redetermination of the Internal Revenue Service determination and not on a general examination of the provisions of the plan or related trust.”
1 later decision quote this exact passage“a case of actual controversy involving--(1) a determination by the Secretary with respect to the initial qualification or continuing qualification of a retirement plan ... or (2) a failure by the Secretary to make a determination with respect to--(A) such initial qualification, or (B) such continuing qualification if the controversy arises from a plan amendment or plan termination ....”
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.