United States v. Adam’s Empirical Analysis

Citation profile

18 federal appellate ·

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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[u]nder a plain reading of this statute, we find it clear that violations of § 7202 are subject to a six-year statute of limitations under § 6531(4). Specifically, 26 U.S.C. § 7202 makes it an offense for an employer to willfully fail to “account for and pay over” to the IRS taxes withheld from employees. Given that § 6531 pertains to “failing to pay any tax,” the District Court correctly found that the failure to pay third-party taxes as covered by § 7202 constitutes failure to pay “any tax,” and thus, is subject to the six-year statute of limitations under § 6531(4).”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Blanchard

2. “[i]f (1) the defendant willfully obstructed or impeded, or attempted to obstruct or impede, the administration of justice with respect to the investigation, prosecution, or sentencing of the instant offense of conviction, and (2) the obstructive conduct related to (A) the defendant's offense of conviction and any relevant conduct; or (B) a closely related offense, increase the offense level by 2 levels.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Pawlak

3. “Where a factual finding is plausible in light of the record as a whole, it is not clearly erroneous. Unless left with the definite and firm conviction that a mistake has been committed, [we] will not deem the district court's finding to be clearly erroneous.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Pawlak