Fegan v. Commissioner’s Empirical Analysis
1979
Citation profile
9
cited by 9 later decisions
September 1987
most recently cited
Relationships
Applies 26 U.S.C. § 48 · 26 U.S.C. § 482
Relies on Helvering v. Wilshire Oil Co. · Ach v. Commissioner of Internal Revenue · Ach v. Commissioner · Hazard v. Commissioner · Rubin 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the amount of rent which was charged, or would have been charged for the use of the same or similar property, during the time it was in use, in independent transactions with or between unrelated parties under similar circumstances * * *.”
2 later decisions quote this exact passage · from the majority“a controlled taxpayer on a tax parity with an uncontrolled taxpayer, by determining, according to the standard of an uncontrolled taxpayer, the true taxable income from the property and business of a controlled taxpayer.”
2 later decisions quote this exact passage · from the majority“it engages in the trade or business of renting property of the same general type as the property in question to unrelated parties.”
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.