Wagner v. United States’s Empirical Analysis
573 F.2d 447 · 1978
Citation profile
21 federal appellate · 2 district · 10 state decisions
How this case has been cited
Cited by 51 later decisions — most recently April 2019 · most notably Textile Banking Co. v. Rentschler (1981), Charles v. Carey (1980)
21 federal appellate · 2 district · 10 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. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6323 · 26 U.S.C. § 6331 · 26 U.S.C. § 7426
Relies on Singleton v. Wulff · Aquilino v. United States · House v. Stynchcombe · Stern v. United States Gypsum, Inc. · Desert Palace, Inc. v. Salisbury
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Taxpayer's] future wages and commissions were contingent on his continued employment and thus did not represent an existing property right to which a lien [ 3 ] could attach. [Taxpayer] had no present right to the wages and commissions.”
2 later decisions quote this exact passage · from the majority“'Whenever the act done takes effect as to some purposes, and is void as to persons who have an interest in impeaching it, the act is not a nullity, and therefore, in a legal sense, is not utterly void, but merely voidable.'”
2 later decisions quote this exact passage · from the majority“[t]hey are contingent upon performance of a contract of service and represent no existing rights of property.”
2 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.