United States v. Khalife’s Empirical Analysis
106 F.3d 1300 · 1997
Citation profile
14 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 24 later decisions — most recently July 2021
14 federal appellate · 2 district · 1 state decisions
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 18 U.S.C. § 2 · 18 U.S.C. § 371 · 26 U.S.C. § 7206 · 31 U.S.C. § 5322 · 31 U.S.C. § 5324 (§ 1354 of the Money Laundering Control Act of 1986)
Relies on Ratzlaf et Ux United States · California v. ARC America Corp. · Air Line Pilots Ass'n, International v. Shugrue · Withrow v. Williams · Alexander 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is unnecessary to refer to any substantive offense when charging a section 371 conspiracy to defraud, and it is also unnecessary to prove the elements of a related substantive offense.”
2 later decisions quote this exact passage · from the majority“First, [in Minarik;] there was a great deal of confusion resulting from the government’s shifting theories of prosecution and failure to clearly define the intent element in the indictment. The one-count indictment in Minarik vaguely charged the defendants with conspiring “to defraud the United States by impeding, impairing, obstructing and defeating the lawful functions of the Department of the Treasury.”... Second, the Minarik defendants’ conduct consisted of one limited act of concealing the proceeds of a real estate transaction to prevent a levy upon the proceeds by the IRS. The breadth of the activity was not commensurate with the Minarik court’s conception of a general conspiracy to defraud.... Third, the Minarik defendants’ duties were sufficiently technical to warrant more specific notice[.]”
1 later decision quote this exact passage · from the majority“unlawfully, willfully and knowingly conspire[d] and agree[d] together and with each other to defraud the United States for the purpose of impeding, impairing, obstructing, and defeating the lawful Government functions of the Internal Revenue Service (IRS) of the Treasury Department in the ascertainment, computation, assessment, and collection of revenue; to wit, income taxes.”
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.