In re Proactive Technologies, Inc.’s Empirical Analysis
1997
Citation profile
Relationships
Applies 11 U.S.C. § 505 · 26 U.S.C. § 6672 · 26 U.S.C. § 7421 · 28 U.S.C. § 1334 · 28 U.S.C. § 157
Relies on Turner v. Davis, Gillenwater & Lynch · Quattrone Accountants, Inc. v. Internal Revenue Service · American Bicycle Association American Bicycle Association v. United States Internal Revenue Service
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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Section 6672(a) imposes liability on a person who (1) is responsible for paying the taxes, and (2) willfully fails to pay the taxes. Section 6672 imposes a one hundred percent penalty on persons responsible who fail to pay the tax. A “responsible person’s” liability under Section 6672, if any, is “entirely separate and distinct” from the corporate entity’s liability for failure to pay 941 taxes, even though the liability arises from failure to pay the same withholding taxes. See Quattrone Accountants, Inc. v. Internal Revenue Service, 895 F.2d 921, 926 (3d Cir.1990). Similarly, Holt’s liability as a responsible person, if any, is “entirely separate and distinct” from Solutions’ liability to the Service, even though the liability arises from failure to pay the same withholding taxes.”
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.