Murray v. United States’s Empirical Analysis
686 F.2d 1320 · 1982
Citation profile
30 federal appellate · 11 district · 1 state decisions
How this case has been cited
Cited by 63 later decisions — most recently July 2023 · most notably Murray v. United States (1987), Cameron v. Internal Revenue Service (1985)
30 federal appellate · 11 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. § 6335 · 26 U.S.C. § 6337 · 26 U.S.C. § 7422 · 26 U.S.C. § 7426 · 28 U.S.C. § 1331 · 28 U.S.C. § 1340 · 28 U.S.C. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 1356
Relies on United States v. Mitchell · United States v. King · Davis v. Passman · Carlson v. Green · Houltin 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 63 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Appellant proposes a narrow construction of the exception, arguing that tax collection efforts were complete when the property was conveyed to the United States at the tax sale for the statutorily calculated minimum bid. He points out that he has not challenged as improper the IRS’s assessment of taxes against the Fireside, Inc. He thus urges the conclusion that this lawsuit arises from rights which postdate the government’s collection efforts. Allegedly, his legal action will not interfere with these efforts. We [cannot] agree that appellant’s claim arises outside of “the assessment or collection of taxes” for purposes of the exception to FTCA jurisdiction. When at a tax sale property is adjudicated to the government at the statutory minimum price, see 26 U.S.C. 6835(e)(1), the government in effect becomes the purchaser subject to the statutory right of redemption. 26 U.S.C. 6337(b)(1). Capital Savings Association v. Runnels, 361 So.2d 458, 462 (La.Ct.App.1978). The right of redemption arises only in connection with the tax levy, and is an integral facet of such a levy. A claim founded on redemption rights is clearly a claim “arising in respect of the collection of a tax” within the meaning of Section 2680(c).”
3 later decisions quote this exact passage“to quiet title to ... real or personal property on which the United States has or claims a mortgage or other lien.”
2 later decisions quote this exact passagee.g. Chow Md · Chow v. Giordano“The owners of any real properly sold as provided in Section 6335, their heirs, executors, or administrators, or any person having any interest therein, or a lien thereon, or any person on their behalf, shall be permitted to redeem the property sold, or any particular tract of such property, at any time within 180 days afler the sale thereof.”
1 later decision quote this exact passage
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.