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← 80 TC 672 - Thompson Engineering Co. v. Commissioner

Thompson Engineering Co. v. Commissioner’s Empirical Analysis

1983

Citation profile

8
cited by 8 later decisions
July 1997
most recently cited

1 federal appellate ·

Relationships

Relies on Helvering v. National Grocery Co. · United States v. Donruss Co. · Ivan Allen Company v. United States · United Business Corp. of America v. Commissioner · United Business Corp. of Am. 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[T]he Bardahl formula is an attempt to inject a degree of objectivity into a quantification of business needs; it is a tool to be used when helpful and its use is not mandated in all events.”
    2 later decisions quote this exact passage
    e.g. EMI Corp. v. Commissioner · Jh Rutter Rex Mfg Company Inc v. Commissioner of Internal Revenue
  2. “formed or availed of for the purpose of avoiding the income tax with respect to its shareholders.”
    1 later decision quote this exact passage
    e.g. Thompson Engineering Co. v. Commissioner
  3. “'taxable income adjusted in the manner provided in section 535(b)'.”
    1 later decision quote this exact passage
    e.g. Thompson Engineering Co. v. Commissioner

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.