Botta v. Scanlon’s Empirical Analysis
314 F.2d 392 · 1963
Citation profile
40 federal appellate · 7 district · 2 state decisions
How this case has been cited
Cited by 100 later decisions (1 by the Supreme Court) — most recently November 2011 · most notably United States v. Sotelo (1978), Robert W. Monday v. United States of America, and Third-Party v. John A. Monday, Third-Party (1970)
40 federal appellate · 7 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. § 7421
Relies on Enochs v. Williams Packing & Navigation Co. · United States v. Graham · National Foundry Co. of N. Y., Inc. v. Director of Internal Revenue · Reams v. Vrooman-Fehn Printing Co.
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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“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, in addition to other penalties provided by law, be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over.”
5 later decisions quote this exact passage““any reference in this title [which includes the Anti-Injunction Statute] to ‘tax’ imposed by this title shall be deemed also to refer to the penalties and liabilities provided by this subchapter [which includes Section 6672].””
5 later decisions quote this exact passage“'is simply a means of insuring that the tax is paid.'”
5 later decisions quote this exact passage
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.