United States v. Evangelista’s Empirical Analysis
122 F.3d 112 · 1997
Citation profile
18 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 46 later decisions — most recently August 2023 · most notably United States v. Thayer (1999), Evangelista v. Ashcroft (2004)
18 federal appellate · 1 district · 2 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. § 371 · 26 U.S.C. § 6531 · 26 U.S.C. § 7201 · 26 U.S.C. § 7202 · 26 U.S.C. § 7215 · 26 U.S.C. § 7512
Relies on United States v. Young · Cheek v. United States · Williamson v. United States · United States v. Pomponio · United States v. Beech-Nut Nutrition Corp.
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]hat Congress intended to make such a distinction is simply inconceivable.”
2 later decisions quote this exact passage · from the majority“Willful failure to collect or pay over tax.”
2 later decisions quote this exact passage · from the majority“plain language of the disputed passage in [26 U.S.C.] § 7202 creates a dual obligation - to `truthfully account for and pay over' trust fund taxes - that is satisfied only by fulfilling both separate requirements. Accordingly, the command of the statute is violated by one `who willfully fails' either to `account for' or to `pay over' the necessary funds.”
1 later decision quote this exact passage · from the majoritye.g. Gibson v. Com.
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.