Computer Programs Lambda, Ltd. v. Commissioner’s Empirical Analysis
1988
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 21 later decisions — most recently October 2017
3 federal appellate ·
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 Link v. Wabash Railroad · Roadway Express, Inc. v. Piper · United States v. Baggot · Amos v. Board of School Directors of City of Milwaukee · Computer Programs Lambda, Ltd. 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“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“Where a partnership is without a tax matters partner before this Court, we believe it is most appropriate for the Court to appoint the partnership’s tax matters partner, rather than for [the Commissioner] to make the appointment because [the Commissioner] is the partnership's adversary during the litigation. An adversary should not appoint an opponent’s representative.”
1 later decision quote this exact passage“acting in an administrative capacity solely for the litigation of this case.”
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.