United States v. Coson’s Empirical Analysis
286 F.2d 453 · 1961
Citation profile
48 federal appellate · 20 district · 6 state decisions
How this case has been cited
Cited by 104 later decisions — most recently December 2018 · most notably Elias v. Wh Connett (1990), De Masters v. Arend (1963)
48 federal appellate · 20 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
Relies on Griffin v. People of the State of Illinois · Skelly Oil Co. v. Phillips Petroleum Co. · Romero v. International Terminal Operating Co. · Hurn v. Oursler · Bull 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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The district courts shall have original jurisdiction of any civil action arising under any Act of Congress providing for internal revenue.”
5 later decisions quote this exact passage · from the majority“In holding as we do that the lack of proper notice or demand was fatal to the acquisition of the Government’s lien against Coson, the emphasis here is somewhat different than that employed by the trial judge who held that the assessment itself was void as against Coson because the taxes were never assessed to Coson, the record of assessment in the office of the Bureau making no reference whatever to Coson. The Government argues that there is no requirement that an assessment be made against any person. Although our decision as to the lack of proper notice or demand is sufficient to dispose of this case, it would appear that the trial court was right in holding the assessment was insufficient for failure to comply with the statutory requirements.”
3 later decisions quote this exact passage · from the majority“[i]f any person liable to pay any tax neglects or refuses to pay the same after demand, the amount ... 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.”
3 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.