United States v. Galletti’s Empirical Analysis
2004
Citation profile
49 federal appellate · 12 district · 6 state decisions
How this case has been cited
Cited by 137 later decisions (9 by the Supreme Court) — most recently March 2025 · most notably Hibbs Director Arizona Department of Revenue v. Winn et al. (2004), Loving v. Internal Revenue Service (2014)
49 federal appellate · 12 district · 6 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.
Appellate journey
reviewedUnited States ex rel. Internal Revenue Service v. Galletti (from Ninth Circuit Court of Appeals)
Relationships
Applies 11 U.S.C. § 101 (Bankruptcy Abuse Prevention and Consumer Protection Act of 2005) · 11 U.S.C. § 362 · 26 U.S.C. § 6201 · 26 U.S.C. § 6203 · 26 U.S.C. § 6501 · 26 U.S.C. § 6511
Relies on United States v. Williams · United States v. Updike · United States v. Wright · In Re Hutching
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 137 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Once a tax has been properly assessed, nothing in the [Internal Revenue] Code requires the IRS to duplicate its efforts by separately assessing the same tax against individuals or entities who are not the actual taxpayers but are, by reason of state law, liable for payment of the taxpayer’s debt. The consequences of the assessment — in this case the extension of the statute of limitations for collection of the debt — attach to the tax debt without reference to the special circumstances of the secondarily liable parties.”
3 later decisions quote this exact passage · from the majority“[T]he term 'assessment' refers to little more than the calculation or recording of a tax liability.”
2 later decisions quote this exact passage · from the majority“'assessment' refers to little more than the calculation or recording of a tax liability.”
2 later decisions quote this exact passage
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.