Munford, Inc. v. Commissioner’s Empirical Analysis
1986
Citation profile
5 federal appellate · 1 district ·
How this case has been cited
Cited by 21 later decisions — most recently May 2016
5 federal appellate · 1 district ·
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 Evans v. Commissioner · Frank J. Evans and Margueritte A. Evans v. Commissioner of Internal Revenue · Yellow Freight System, Inc. v. United States · Illinois Cereal Mills, Inc. v. Commissioner · Brown-Forman Distillers Corp. v. United States
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We think that the principal purpose or function of the refrigerated area is not to furnish working space for petitioner’s employees, but rather, to provide an area in which frozen foods may be stored at low temperature. In contrast with the truck and rail loading platforms [also at issue in Munford], the refrigerated area of the Addition is maintained at a temperature which limits, rather than promotes, human activity. Due to the cold temperature, the activities of petitioner’s employees are limited in both scope and duration. In the case of the Addition’s refrigerated area, the structure itself serves the principal function of low temperature storage of products, and the activities of petitioner’s employees are merely supportive of and ancillary to this function. Accordingly, we conclude that the refrigerated portion of the Addition is not a building under the functional test. [ 87 T.C. at 483 .]”
2 later decisions quote this exact passage · from the majority“In reviewing this determination, we begin with the premise that “in the investment tax credit context, the term ‘building’ has become a term of art,” notwithstanding Congress’ original intent that the term be accorded its commonly accepted meaning.”
2 later decisions quote this exact passage · from the majority“the term “section 38 property” means— (A) tangible personal property (other than an air conditioning or heating unit), or (B) other tangible property (not including a building and its structural components) but only if such property— (i) is used as Em integral part of manufacturing, production, or extraction or of furnishing transportation, communications, electrical energy, gas, water, or sewage disposal services, * * * [[Image here]] Such term includes only recovery property (within the meaning of section 168 without regard to any useful life) and any other property with respect to which depreciation (or amortization in lieu of depreciation) is allowable and having a useful life (determined as of the time such property is placed in service) of 3 years or more.”
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.