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← 317 U.S. 329 - Detroit Bank v. United States

Detroit Bank v. United States’s Empirical Analysis

317 U.S. 329 · 1943

Citation profile

325
cited by 325 later decisions
17
cited 17 times by the Supreme Court
12
states following
May 2023
most recently cited

157 federal appellate · 41 district · 35 state decisions

How this case has been cited

Cited by 325 later decisions (17 by the Supreme Court) — most recently May 2023 · most notably Bolling v. Sharpe (1954), Adarand Constructors, Inc. v. Pena (1995)

157 federal appellate · 41 district · 35 state decisions — followed in 12 states

930194319501960197019801990200020102020decided

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.

Appellate journey

reviewedPaul v. United States (from Sixth Circuit Court of Appeals)

Relationships

Relies on Sunshine Anthracite Coal Co. v. Adkins · Chas Steward Mach Co v. Davis · Ithaca Trust Co. v. United States · Currin v. Wallace · Tyler 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 325 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““The [estate tax] lien attaches at the date of the decedent’s death, since the gross estate is determined as of that date and the estate tax itself becomes an obligation of the estate at that time without assessment. [Cases cited.]” [Emphasis supplied.] 2”
    3 later decisions quote this exact passage · from the majority
  2. “Section 3670. Property subject to lien "If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, penalty, additional amount, or addition to such tax, together with any costs that may accrue in addition thereto) 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.”
    2 later decisions quote this exact passage · from the majority
  3. ““The [general tax lien] is upon all the property of the person liable for the tax, while the [special estate tax lien] attaches only to the property included in and taxed as the gross estate not used to pay administration expenses. The [general tax lien] continues until the tax liability is paid while the [special estate tax lien] continues for ten years from the death of the decedent. Of particular significance is the difference in time when the liens attach under the two sections. Under the [general tax lien provisions] there is no lien and no notice can be recorded until there has been a demand by the collector and a refusal to pay it by the taxpayer. Under [the special estate tax lien provisions] as has been stated, the lien arises on the death of the decedent and becomes effective against purchasers and mortgagees without assessment or demand and obviously before it would be possible to record a notice of lien under the [general tax lien provisions]."”
    1 later decision 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.