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← 91 TC 1069 - Chomp Assoc. v. Commissioner

Chomp Assoc. v. Commissioner’s Empirical Analysis

1988

Citation profile

27
cited by 27 later decisions
February 2016
most recently cited

How this case has been cited

Cited by 27 later decisions — most recently February 2016 · most notably Columbia Bldg. v. Commissioner (1992), 1983 Western Reserve Oil & Gas Co. v. Commissioner (1990)

1501988199020002010decided

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 Welch v. Helvering · Commissioner of Internal Revenue v. South Texas Lumber Co · United States v. Vogel Fertilizer Co. · Shelton v. Commissioner · 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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Since the identity of the TMP may not be known to the Secretary, mailing of any notice in care of the tax matters partner at the address where the partnership business is carried on will constitute mailing of the notice for purposes of determining whether other requirements imposed on the Secretary are complied with or whether any action, such as mailing notices to other partners, is timely taken. [H. Rept. 97-760 (Conf.) (1982), 1982- 2 C.B. 600 , 663.]”
    2 later decisions quote this exact passage
  2. “For purposes of subchapter C of chapter 63 of the Code, a notice is treated as mailed to the tax matters partner on the earlier of— (1) the date on which the notice is mailed to “THE TAX MATTERS PARTNER” at the address of the partnership (as provided on the partnership return * * * ), or (2) the date on which the notice is mailed to the person who is the tax matters partner at the address of that person (as provided on the partner’s return * * * ) or the partnership. * * *”
    1 later decision quote this exact passage
  3. “(7) Tax matters partner. The tax matters partner of any partnership is— (A) the general partner designated as the tax matters partner as provided in regulations, or (B) if there is no general partner who has been so designated, the general partner having the largest profits interest in the partnership at the close of the taxable year involved (or, where there is more than 1 such partner, the 1 of such partners whose name would appear first in an alphabetical listing).”
    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.