26 U.S.C. § 7501
Section 7501 · Liability for taxes withheld or collected
Amended 1 time on record
Applied in 486 court decisions — leading case United States v. Whiting Pools, Inc. (1983)
Most recently applied in Faisal Ahmed v. Commissioner of IRS (April 2023)
Applied most in the Ninth Circuit Circuit (25 decisions)
Cases citing this section usually also cite 26 U.S.C. § 6672 · 26 U.S.C. § 3102 · 26 U.S.C. § 6671
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
Whenever any person is required to collect or withhold any internal revenue tax from any other person and to pay over such tax to the United States, the amount of tax so collected or withheld shall be held to be a special fund in trust for the United States. The amount of such fund shall be assessed, collected, and paid in the same manner and subject to the same provisions and limitations (including penalties) as are applicable with respect to the taxes from which such fund arose.
For penalties applicable to violations of this section, see sections 6672 and 7202.