United States v. Equitable Life Assurance Soc. of United States’s Empirical Analysis
1966
Citation profile
128 federal appellate · 43 district · 72 state decisions
How this case has been cited
Cited by 386 later decisions (4 by the Supreme Court) — most recently May 2025 · most notably United States 77-1359 v. Kimbell Foods Inc (1979), United States v. McCombs (1994)
128 federal appellate · 43 district · 72 state decisions — followed in 17 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.
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 Sprage v. Ticonic Nat Bank · United States v. City of New Britain · Trustees v. Greenough · United States v. Security Trust & Savings Bank · United States v. Pioneer American Insurance
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 386 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he relative priority of a state lien is determined by the rule `first in time is first in right,' which in turn hinges upon whether, on the date the federal lien was recorded, the state lien was `specific and perfected.' A state lien is specific and perfected when `there is nothing more to be done * * * — when the identity of the lienor, the property subject to the lien, and the amount of the lien are established.' Thus, the priority of each statutory lien * * * must depend on the time it attached to the property in question and became choate.' United States v. City of New Britain, supra.”
12 later decisions quote this exact passage · from the majority““If any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand, the district director * * * may proceed to collect the tax by levy upon any property, or rights to property, whether real or personal, tangible or intangible, belonging to such person or on which there is a lien provided by [the statute] * * * for the payment of such tax. * * * Levy may be made by serving a notice of levy on any person in possession of, or obligated with respect to, property or rights to property subject to levy. * * *” (Emphasis added.)”
5 later decisions quote this exact passage · from the majority““(a) Purchases [sic], holders of security interest, mechanic’s lienors, and judgment lien creditors. — The lien imposed by section 6321 shall not be valid as against any purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor until notice thereof which meets the requirements of subsection (f) has been filed by the Secretary or his delegate. ***** “(c) Protection for certain commercial transactions financing agreements, etc.— 'll) In general. — To the extent provided in this subsection, even though notice of a lien imposed by .section 6321 has been filed, such lien shall not be valid with respect to a security interest which came into existence after tax lien filing but which— ***** “(iii) an obligatory disbursement agreement, and “(B) is protected under local law against a judgment lien arising, as of the time of tax lien filing, out of an unsecured obligation. ***** “(4) Obligatory disbursement agreement. — For purposes of this subsection — • “(A) Definition. — The term ‘obligatory disbursement agreement’ means an agreement (entered into by a person in the course of his trade or business) to make disbursements, but such an agreement shall be treated as coming within the term only to the extent of disbursements which are required to be made by reason of the intervention of the rights of a person other than the taxpayer. “(B) Limitation on qualified property. —The term ‘qualified property’, when used with respect to an obligatory disbursement agr”
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.