Bank of Nevada v. United States’s Empirical Analysis
251 F.2d 820 · 1957
Citation profile
37 federal appellate · 10 district · 6 state decisions
How this case has been cited
Cited by 77 later decisions (1 by the Supreme Court) — most recently February 2013 · most notably United States v. National Bank of Commerce (1985), United States v. Sterling National Bank & Trust Co. of New York (1974)
37 federal appellate · 10 district · 6 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 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966)
Relies on United States v. City of New Britain · United States v. Security Trust & Savings Bank · United States v. Acri · United States v. Waddill, Holland & Flinn, Inc. · People of State of Illinois Gordon v. Campbell
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 77 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, additional amount, addition to tax, or assessable penalty, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.” (Emphasis supplied.) 26 U.S.C.A. § 6321 .”
2 later decisions quote this exact passage · from the majority““The Supreme Court has repeatedly and emphatically stated that Federal tax liens and the provisions for their collection are strictly Federal and strictly statutory.” (Many authorities cited and quoted)”
2 later decisions quote this exact passage · from the majority“SURRENDER OF PROPERTY SUBJECT TO A LEVY. (a) Requirement. — Except as otherwise provided in subsection (b), any person in possession (or obligated with respect to) property rights or property subject to levy upon which a levy has been made shall, upon demand of the Secretary, surrender such property or rights (or discharge such obligation) to the Secretary, except such part of the property or rights as is, at the time of such demand, subject to an attachment or execution under any judicial process____ (c) Enforcement of levy.— (1) Extent of personal liability. — Any person who fails or refuses to surrender any property or right to property, subject to levy, upon demand by the Secretary shall be liable in his own person and estate to the United States in a sum equal to the value of property or rights not so surrendered, but not exceeding the amount of taxes for the collection of which such levy has been made, together with costs and interest on such sum at an annual rate established under section 6621 from the date of such levy (or, in the case of a levy described in section 6331(d)(3), from the date such person would otherwise have been obligated to pay over such amounts to the taxpayer). Any amount (other than costs) recovered under this paragraph shall be credited against the tax liability for the collection of which such levy was made. (2) Penalty for violation. — In addition to the personal liability imposed by paragraph (1), if any person required to surrender property o”
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.