Kizzier v. United States’s Empirical Analysis
598 F.2d 1128 · 1979
Citation profile
27 federal appellate · 4 district ·
How this case has been cited
Cited by 47 later decisions — most recently March 2010 · most notably Davis v. United States (1992), Muck v. United States (1993)
27 federal appellate · 4 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
Relies on Slodov v. United States · Mazo v. United States · Hartman v. United States · Teel v. United States · Maggy v. United States
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"(a) General Rule. 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."”
3 later decisions quote this exact passage · from the majority“Although [the plaintiff] did not become aware of [the corporation’s] tax delinquency until March 1974, he was a responsible person ... through all the calendar quarters [the corporation] failed to pay over employment taxes to the Government. As such, [the plaintiff’s] responsibility to pay [the corporation’s] withheld employment taxes extended to unencumbered funds received by the corporation after [the plaintiff] learned of [the corporation’s] tax delinquency.”
2 later decisions quote this exact passage · from the majority“Where corporate withholdings are involved, a responsible person is normally a managing officer or employee of the corporation, but he need not be such an officer or employee, and there may be more than one responsible person. A corporate officer or employee is responsible in present context if he has significant, albeit not necessarily exclusive, authority in the field of corporate decision-making and action where taxes due the federal government are concerned; but he need not be an actual disbursing officer.”
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.