Morrison Incorporated v. Commissioner of Internal Revenue’s Empirical Analysis
Citation profile
5 federal appellate ·
Relationships
Applies 26 U.S.C. § 38 · 26 U.S.C. § 48
Relies on Walker v. Illinois · Miller v. Commissioner of Internal Revenue · Kirchman v. Commissioner · Piggly Wiggly Southern, Inc. v. Commissioner · Piggly Wiggly Southern, Inc. 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“any tangible property except land and improvements thereto, such as buildings or other inherently permanent structures (including items which are structural components of such buildings or structures)”
5 later decisions quote this exact passage · from the majority“does not include machinery the sole justification for the installation of which is the fact that such machinery is required to meet temperature or humidity requirements which are essential for the operation of other machinery or the processing of materials or foodstuffs. Machinery may meet the”
3 later decisions quote this exact passage · from the majority“. This wood deck was constructed at ground level and covered the entire module. Thus, although it provided employee access to the anechoic chambers, it also provided access and work space for the entire module. Also, it did not provide structural support for equipment in the module and it was not established that it was an essential part of any specific items of machinery or equipment. Compare Rev. Rul. 74-391 , 1974- 2 C.B. 9 , upon which petitioner relies. On these facts, we conclude that this wood deck related to the operation or maintenance of a building and is a”
1 later decision 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.