Szerlip v. Marcelle’s Empirical Analysis
1955
Citation profile
7 federal appellate ·
Relationships
Applies 26 U.S.C. § 7421 · 26 U.S.C. § 7422 · 26 U.S.C. § 7424 · 28 U.S.C. § 1340 · 28 U.S.C. § 2463
Relies on Raffaele v. Granger · Rothensies v. Ullman · Tomlinson v. Smith · Long v. Rasmussen · Stuart v. Chinese Chamber of Commerce of Phœnix
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is settled law that nondelinquent third-parties, whose property has been taken by the Collector of Internal Revenue for the tax liability of another, may maintain actions in the Federal District Courts under this section, to stay the sale thereof, without being bound by provisions of the Internal Revenue Code forbidding suits restraining the assessment of tax (now See. 7421 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 7421 ). Long v. Rasmussen, D.C.Mont., 281 F. 236 ; Rothensies v. Ullman, 3 Cir., 110 F.2d 590 ; Tomlinson v. Smith, 7 Cir., 128 F.2d 808 ; Raffaele v. Granger, 3 Cir., 196 F.2d 620 .””
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.