Huizinga v. United States’s Empirical Analysis
68 F.3d 139 · 1995
Citation profile
9 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 33 later decisions — most recently May 2017 · most notably United States v. Kim (1997), 346 F. Supp. 2d 92 - Calvetti v. Antcliff (2004)
9 federal appellate · 3 district · 1 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. § 6672 · 26 U.S.C. § 7501
Relies on Anderson v. Liberty Lobby, Inc. · Celotex Corporation v. Catrett H · MacArthur Co. v. Johns-Manville Corp. · Shaw v. Barr · Pinney Dock & Transport Co. v. Penn Central Corp.
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the building construction industry, the building contract fund paid by any person to a contractor, or by such person or contractor to a subcontractor, shall be considered by this act to be a trust fund, for the benefit of the person making the payment, contractors, laborers, subcontractors or materialmen, and the contractor or subcontractor shall be considered the trustee of all funds so paid to him for building construction purposes.”
5 later decisions quote this exact passage · from the majority“A responsible person who first becomes aware of a past due withholding tax liability after the liability has accrued is considered willful (for purposes of section 6672) if he fails to use all unencumbered funds that come into his possession thereafter to pay the delinquent taxes. Funds are considered encumbered only where the taxpayer is legally obligated to use the funds for a purpose other than satisfying the preexisting employment tax liability and [the] legal obligation is superior to the interest of the IRS in the funds.”
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.