538 F. Supp. 504 - Howard v. Adle’s Empirical Analysis
1982
Citation profile
4 federal appellate · 5 district · 1 state decisions
How this case has been cited
Cited by 13 later decisions — most recently August 2006
4 federal appellate · 5 district · 1 state decisions
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. § 6335 · 26 U.S.C. § 6337 · 26 U.S.C. § 7701 · 28 U.S.C. § 1340 · 28 U.S.C. § 2410
Relies on Aqua Bar & Lounge, Inc. v. United States Department of Treasury Internal Revenue Service · Keely v. Sanders · Hoehn v. Crews · Reece v. Scoggins · McAndrews v. Belknap
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Second, in neither case did the undisputed facts show that the taxpayer received prior written notice of the sale. In Reece not only was there no personal service, but notice of the sale was not mailed in time to be delivered prior to the sale date, and no notice of the adjourned sale date was mailed. Thus there was a substantial issue whether the taxpayer had been given “an opportunity to be present at the tax sale and bid on the property”, the central purpose of the statutory notice requirements. 506 F.2d at 971 . The court in Aqua Bar refused to speculate as to whether mailed notice of sale had actually reached the taxpayer because the “purpose of requiring a particular method of giving notice is to prevent disputes over whether notice was received”. 438 F.Supp. at 657 . (Emphasis added).”
1 later decision quote this exact passage · from the majority“original notice of sale will be delivered to the taxpayer personally”
1 later decision quote this exact passage · from the majority“arising under any Act of Congress providing for internal revenue....”
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.