United States v. Perry’s Empirical Analysis
473 F.2d 643 · 1973
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 10 later decisions — most recently October 2002
7 federal appellate · 1 district ·
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. § 6322 · 28 U.S.C. § 2410
Relies on United States v. Brosnan · Dorothy Evans Anderson Etc. v. Dr. M. L. Moorer · 231 F. Supp. 718 - Quinn v. Hook · Cheney v. Nathan · Lanza v. Metcalf
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(b) The complaint or pleading shall set forth with particularity the nature of the interest or lien of the United States. In actions or suits involving liens arising under the internal revenue laws, the complaint or pleading shall include the name and address of the taxpayer whose liability created the lien and, if a notice of the tax lien was filed, the identity of the internal revenue office which filed the notice, and the date and place such notice of lien was filed. In actions in the State courts service upon the United States shall be made by serving the process of the court with a copy of the complaint upon the United States attorney for the district in which the action is brought or upon an assistant United States attorney or clerical employee designated by the United States attorney in writing filed with the clerk of the court in which the action is brought and by sending copies of the process and complaint, by registered mail, or by certified mail to the Attorney General of the United States at Washington, District of Columbia. In such actions the United States may appear and answer, plead or demur within sixty days after such service or such further time as the court may allow.”
1 later decision quote this exact passage · from the majority“was in response to the recognized need for a way to force disputes over government tax liens to resolution, rather than leaving the United States in complete control of the timing.”
1 later decision quote this exact passage · from the majority“justice and fair dealing would require that a method be provided to clear real-estate titles of questionable or valueless government liens.”
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.