City of Philadelphia v. The Collector’s Empirical Analysis

Citation profile

25 federal appellate · 19 district · 9 state decisions

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 115 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Where the party voluntarily pays the money he is without remedy; hut if he pays It by compulsion of law, or under protest, or with notice that he intends to bring suit to test the validity of the claim, he may recover it back, if the assessment was erroneous or illegal, in an action of assumpsit for money had and received.””

   6 later decisions quote this exact passage · from the majority
   e.g. Johnson & Johnson v. Herold · Fox v. Edwards

2. ““Undoubtedly tbe original act of 1833 was passed for the protection of officers of the revenue; and persons acting under them, charged by law with the collection of import duties, and the first proviso in the sixty-seventh section of the act of the thirteenth of July, 1866, expressly enacts that the original act shall not be so construed as to apply to cases ‘arising under any of the internal revenue acts, nor to any case in which the validity or interpretation of those acts shall be in issue.’ The effect of that proviso is to limit the scope of the original act, without repealing it, to cases arising under the acts of Congress .providing for the collection of import' duties, and to confine its operation to the purposes for which it was originally passed.””

   1 later decision quote this exact passage · from the majority
   e.g. Twin Falls Canal Co. v. Foote

3. ““That the provisions of the act entitled ‘An net to provide for the collection of duties ou imports,’ approved March 2, 1833, now in force, shall be taken and deemed as extended to and embracing all cases arising under the laws for the collection of internal duties, stamp duties, licenses or taxes which have boon, or may be hereafter enacted; and all persons duly authorized to assess, receive or collect such duties or tax under such laws are hereby declared to be, and to have been revenue officers within the true intent and moaning of said act and entitled to ail the exemptions, immunities, rights, benefits and privileges therein enumerated or conferred.””

   1 later decision quote this exact passage · from the majority
   e.g. People's United States Bank v. Goodwin