United States v. Vermont’s Empirical Analysis
1964
Citation profile
106 federal appellate · 57 district · 61 state decisions
How this case has been cited
Cited by 391 later decisions (10 by the Supreme Court) — most recently May 2019 · most notably United States 77-1359 v. Kimbell Foods Inc (1979), United States Internal Revenue Service v. J McDermott (1993)
106 federal appellate · 57 district · 61 state decisions — followed in 15 states
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
reviewedUnited States v. State of Vermont (from Second Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6322 · 26 U.S.C. § 6323
Relies on United States v. City of New Britain · Bull v. United States · United States v. Security Trust & Savings Bank · United States v. Pioneer American Insurance · United States v. Gilbert Associates, Inc.
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 391 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“perfected in the sense that there is nothing more to be done to have a choate lien--when the identity of the lienor, the property subject to the lien, and the amount of the lien are established.”
12 later decisions quote this exact passage · from the majority“If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, additional amount, addition to tax, or assessable penalty, 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.”
9 later decisions quote this exact passage · from the majority“"Section 3466 on its face permits no exception whatever from the statutory command that `[w]henever any person indebted to the United States is insolvent * * * debts due to the United States shall be first satisfied.' The statute applies to all the insolvent's debts to the Government, whether or not arising from taxes, and whether or not secured by a lien."”
6 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.