Mazo v. United States’s Empirical Analysis
591 F.2d 1151 · 1979
Citation profile
100 federal appellate · 8 district · 3 state decisions
How this case has been cited
Cited by 241 later decisions — most recently April 2021 · most notably Howard v. United States (1983), Purcell v. United States (1993)
100 federal appellate · 8 district · 3 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. § 3401 (Tax Adjustment Act of 1966) · 26 U.S.C. § 6672 · 26 U.S.C. § 7501
Relies on United States v. Diebold, Inc. · Poller v. Columbia Broadcasting System, Inc. · Ohio v. Kentucky · Slodov v. United States · Richardson v. Hynson, Westcott & Dunning, Inc.
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 241 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Voluntary, conscious and intentional act such as the payment of other creditors in preference to the United States ... A responsible person also acts wil-fully if he proceeds with a reckless disregard of a known or obvious risk that trust funds may not be remitted to the government.”
11 later decisions quote this exact passage · from the majority“Any person required to collect, truthfully account for, and pay over any tax imposed by this title who willfully fails to collect such tax, or truthfully account for and pay over such tax, or willfully attempts in any manner to evade or defeat any such tax or the payment thereof, shall, in addition to other penalties provided by law, be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over.”
10 later decisions quote this exact passage · from the majority“a special fund [held] in trust for the United States.”
8 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.