Rodriguez v. Escambron Development Corp.’s Empirical Analysis
740 F.2d 92 · 1984
Citation profile
20 federal appellate · 10 district · 1 state decisions
How this case has been cited
Cited by 53 later decisions — most recently March 2018 · most notably Terwilliger's Catering Plus Inc Bavely v. United States Internal Revenue Service (1990), United States v. Wingfield (1987)
20 federal appellate · 10 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. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6323 · 26 U.S.C. § 6325 · 28 U.S.C. § 1292
Relies on United States 77-1359 v. Kimbell Foods Inc · Michel v. United States · United States v. City of New Britain · Aquilino v. United States · O’Callahan v. Parker, Warden
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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“federal law governs whether these rights are 'rights to property' to which a tax lien may attach”
4 later decisions quote this exact passage · from the majority“creates no property rights but merely attaches consequences, federally defined, to rights created under state law.”
2 later decisions quote this exact passage · from the majority“[T]he government’s rights can rise no higher than those of the taxpayer to whom the property belongs; for example, the lien for a partner’s unpaid income taxes attaches to his interest in the firm, not to the firm’s assets. In the same vein, the lien arising from the unpaid taxes of a person who purchased property under a conditional sale or chattel mortgage before the assessment was made attaches to the taxpayer’s equity and is inferior to the seller’s security interest. Moreover, the tax collector not only steps into the taxpayer’s shoes but must go barefoot if the shoes wear out; thus, a state judgment terminating the taxpayer’s rights to an asset also extinguishes the federal tax lien attached thereto.”
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.