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← 334 F.2d 339 - Abel v. Campbell

Abel v. Campbell’s Empirical Analysis

334 F.2d 339 · 1964

Citation profile

35
cited by 35 later decisions
March 2016
most recently cited

15 federal appellate · 2 district ·

How this case has been cited

Cited by 35 later decisions — most recently March 2016 · most notably In re El San Juan Hotel (1987), Resyn Corporation v. United States (1988)

15 federal appellate · 2 district ·

110196419701980199020002010decided

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. · Bull v. United States · Phillips v. Commissioner · Phillips v. Commissioner · Bruning 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “by virtue of the provisions of Section 7421(a) and that the exceptions embodied therein pertaining to Sections 6212(a) and (c), and 6213(a) [the provisions requiring the giving of 90-day notice and the right of appeal to the Tax Court], of the Internal Revenue Code of 1954, are not applicable in this case, because of the application of the provision of Section 6871(a) [the provision that authorizes the government to issue an assessment immediately without notice in the event of a receivership].”
    2 later decisions quote this exact passage · from the majority
  2. “Because the tax liability survives ... the bankruptcy, the bankrupt has standing to attack the proof of claim before the Referee and a right to appeal an adverse judgment as would an ordinary creditor”
    2 later decisions quote this exact passage · from the majority
  3. “despite the restrictions imposed by section 6213(a) upon assessments”
    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.