Scott v. United States’s Empirical Analysis
2009
Citation profile
5 district ·
Relationships
Applies 26 U.S.C. § 6001 · 26 U.S.C. § 6020 · 26 U.S.C. § 6103 · 26 U.S.C. § 6109 · 26 U.S.C. § 6203 · 26 U.S.C. § 6211 · 26 U.S.C. § 6301 · 26 U.S.C. § 6303
Relies on Bell Atlantic Corp. v. Twombly · Scheuer v. Rhodes · Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics · Erickson v. Pardus · Federal Deposit Insurance v. Meyer
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“• 26 U.S.C. § 6301 , by failing to develop and implement procedures concerning the review processes of the decisions to issue liens, levies, and the seizure of property (Count 19); • 26 U.S.C. § 6303 , by failing to give notice to the plaintiff within sixty days after making an assessment of the taxes owed (Count 20); • 26 U.S.C. § 6304 , by engaging in conduct that has the natural consequence to harass, oppress, or abuse the plaintiff in connection with the collection of unpaid tax (Count 21); • 26 U.S.C. § 6320 , by failing to afford the plaintiff a hearing where he could raise the issue of underlying tax liability (Count 22); • 26 U.S.C. § 6321 , by asserting liens without first giving proper notice or making a demand to the plaintiff (Count 23); • 26 U.S.C. § 6751 , by failing to verify in writing that a supervisor had approved, in writing, any initial tax penalty determination (Count 24); • 26 U.S.C. § 6322 , by asserting liens for which no assessment was made in accordance with 26 U.S.C. § 6203 and 26 C.F.R. § 301.6203-1 (Count 25); • 26 U.S.C. § 6323 , by failing to certify notice of hens under Montana state law (Count 26); and • 26 U.S.C. § 7213 , by unlawfully disclosing the plaintiffs tax return information by filing notices of liens in stated amounts for which no record of such assessments exist (Count 27).”
1 later decision quote this exact passage · from the majority“• 26 U.S.C. § 6001 and 26 C.F.R. § 1.6001 -l(d), by failing to notify the plaintiff of the requirement to keep records, make statements, or file returns with respect to any tax imposed in the Code (Counts 1-2); • 26 U.S.C. § 6020 and 26 C.F.R. § 301.6020-1 , by failing to prepare or subscribe any substitute returns in the name of the plaintiff (Counts 3-6); • 26 U.S.C. § 6103 and 26 C.F.R. § 301.6103 (e)-l, by failing to disclose returns bearing the plaintiffs name to the plaintiff or the plaintiffs representative, upon request (Counts 7-8); • 26 U.S.C. § 6109 and 26 C.F.R. § 301.6109-1 , by improperly requiring that the plaintiff obtain and use a Social Security Number (Counts 9-10); • 26 U.S.C. § 6201 and 27 C.F.R. Part 70, by failing to limit the plaintiffs tax assessments, or otherwise incorrectly or impermissibly assessing them and refusing to correct them (Counts 11-13); • 26 U.S.C. § 6203 and 26 C.F.R. § 301.6203-1 , by failing to record or sign the assessments, or furnish signed copies of the assessments to the plaintiff (Counts 14-17); and • 26 U.S.C. § 6211 , by failing to promulgate regulations implementing the portions of the Code defining the term deficiency (Count 18).”
1 later decision quote this exact passage · from the majority“which constitute[s] notice and demand for payment within the meaning of section 6303(a).”
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.