Tran v. Tran’s Empirical Analysis
2017
Citation profile
1 district · 1 state decisions
Relationships
Applies 26 U.S.C. § 6511 · 26 U.S.C. § 6724 · 26 U.S.C. § 7434 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Cheek v. United States · MacKey v. Lanier Collection Agency & Service, Inc. · Nishimatsu Construction Co. v. Houston National Bank · McDonald v. Southern Farm Bureau Life Insurance · In Re Rasbury
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]illfullness requires more than knowledge. To prove willfulness [sic], the plaintiff must show that the defendants, aware of the duty purportedly imposed by Section 7434, specifically intended to flout the statute.”
2 later decisions quote this exact passage“[T]he payor's filing of the wrong form establishes no liability under Section 7434 unless the form willfully misstates the payee's income.”
2 later decisions quote this exact passage“an employer's filing of the wrong information-return form cannot establish liability under Section 7434 unless the form willfully misstates the amount of payment ....”
1 later decision quote this exact passagee.g. Sims v. Unation, LLC
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.