Computer Programs Lambda, Ltd. v. Commissioner’s Empirical Analysis
1987
Citation profile
11 federal appellate · 1 district ·
How this case has been cited
Cited by 58 later decisions — most recently February 2019 · most notably Callaway v. Commissioner (2000), Transpac Drilling Venture 1982-12 v. Commissioner of Internal Revenue (1998)
11 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
Applies 11 U.S.C. § 362
Relies on Maxwell v. Commissioner · McClamma v. Commissioner · Carstenson v. Commissioner · Thompson v. Commissioner · Transpac Drilling Venture 1982-22 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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“that to treat items as partnership items will interfere with the effective and efficient enforcement of this title”
2 later decisions quote this exact passage“the Secretary determines by regulation to present special enforcement considerations.”
2 later decisions quote this exact passage“The tax matters partner's status is of critical importance to the proper functioning of the partnership audit and litigation procedures, and the statute recognizes this status.... The tax matters partner is the central figure of partnership proceedings.... Moreover, the tax matters partner may, under some circumstances, bind partners who are not notice partners by entering into a settlement agreement with respondent. In the execution of these responsibilities a tax matters partner acts as a fiduciary. His personal interest, if any, is beside the point,... The detailed statutory procedures for partnership level audits and litigation contemplate the continual presence of one tax matters partner, and the procedures cannot operate unless the tax matters partner is capable of acting on the partnership's behalf regardless of his personal tax posture. As the fiduciary of the partnership’s interest in the proceeding, the tax matters partner's initiative (or failure to take initiative) is plainly designed to affect the rights of all partners in the partnership.”
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.