United States v. Running’s Empirical Analysis
7 F.3d 1293 · 1993
Citation profile
12 federal appellate · 2 district ·
Relationships
Relies on Gotthelf v. Commissioner · Slodov v. United States · Withrow v. Williams · Universal Builders, Inc. v. Clark · Lambert v. Director, Office of Workers' Compensation Programs
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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“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 ... be liable for 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“The principal component of willfulness is knowledge: a responsible person acted willfully within the meaning of § 6672(a) if he (a) knew of the company’s obligation to pay withholding taxes, and (b) knew that company funds were being used for other purposes instead. Thus, failures were willful within the meaning of § 6672(a) if they were voluntary, conscious and intentional — as opposed to accidental — decisions not to remit funds properly withheld to the Government.”
1 later decision quote this exact passage · from the majority“The government makes much of Running’s admission that he was aware of Bethel’s financial problems while employed by Good Shepard, but knowledge of financial distress, without more, does not equate to knowledge that the facility was not meeting its tax obligations. Id. (emphasis supplied).”
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.