Bloom v. United States’s Empirical Analysis
272 F.2d 215 · 1959
Citation profile
86 federal appellate · 15 district · 2 state decisions
How this case has been cited
Cited by 165 later decisions — most recently December 2007 · most notably Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-Party (1970), White v. United States (1967)
86 federal appellate · 15 district · 2 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. § 1400 · 26 U.S.C. § 1401 · 26 U.S.C. § 7851 · 28 U.S.C. § 1291 · 28 U.S.C. § 1345
Relies on United States v. United States Gypsum Co. · United States v. Updike · United States v. Arizona · Wilson v. United States
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 165 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * 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 * * *”
7 later decisions quote this exact passage · from the majority““Any person required to collect, truthfully account for, and pay over any tax imposed by this title who willfully fails to collect such tax, or truthfully account for and pay over such tax, or willfully attempts in any manner to evade or defeat any such tax or the payment thereof, shall * * * be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over. * * * ” 26 U.S.C. § 6672 .”
5 later decisions quote this exact passage · from the majority“In our view, Section 2707(a) [the predecessor to § 6672] imposes a separate and distinct liability upon the officer of the corporation who has the duty or is responsible for the collection and payment of the tax and who willfully fails either to collect the tax or to pay it over. While this liability is denominated `penalty' it is `to be assessed and collected in the same manner as taxes are assessed and collected.' While it might be said that the assessment made on appellant is derivative of the assessments made on the corporation, in that they both relate to taxes collected or withheld by the corporation, the liability imposed upon appellant by Section 2707(a) is statutory and in such cases the statutory limitations are controlling.”
2 later decisions 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.