Paisner v. O'Connell’s Empirical Analysis
1962
Citation profile
4 federal appellate · 1 district ·
How this case has been cited
Cited by 8 later decisions — most recently May 1983
4 federal appellate · 1 district ·
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 26 U.S.C. § 6203 · 26 U.S.C. § 7851
Relies on Bloom v. United States · Estate of Levi T. Scofield, Douglas F. Schofield, Trustee, Mary Jane Scofield Demmon (Nee Mary Jane Scofield), Roy C. Demmon and Mary Scofield Demmon, Josephine Scholfield Thompson, Edward W. Thompson and Josephine S. Thompson, Douglas F. Schofield Trust, Douglas F. Schofield, Trustee, Douglas F. Schofield and Mary D. Schofile, Field, Schofield Building Land Trust, Douglas F. Schofield, Trustee v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Estate of Levi T. Scofield, Douglas F. Schofield, Trustee · Paddock v. Siemoneit · Frazier v. United States · City of New York v. Rassner
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In our view there need not be present an intent to defraud or deprive the United States of the taxes collected or withheld for its account, nor need bad motives be present in order to invoke the sanctions of Section 2707(a). The decision of appellant as the responsible officer of the corporation not to have the corporation pay over to the government the withheld taxes was a voluntary, conscious, and intentional act to prefer other creditors of the corporation over the United States. In our view such conduct was willful within the meaning of Section 2707(a).””
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.