Schussel v. Werfel’s Empirical Analysis
758 F.3d 82 · 2014
Citation profile
5 federal appellate ·
Relationships
Applies 26 U.S.C. § 311 · 26 U.S.C. § 6214 · 26 U.S.C. § 6601 · 26 U.S.C. § 6901 · 26 U.S.C. § 6902 · 26 U.S.C. § 7482 · 26 U.S.C. § 7501 · 28 U.S.C. § 3304
Relies on Commissioner v. Stern · Commissioner of Internal Revenue v. F Tellier · United States v. Craft · Nicholas v. United States · Billings 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[F]or example, if the taxpayer owes $100 in taxes, upon which $30 in interest accrues, and the taxpayer then fraudulently transfers $150 to a transferee, the IRS can certainly recover a judgment of no less than $130 against the transferee.”
2 later decisions quote this exact passage · from the majority“[t]he IRS may recover from [the transferee] all amounts [the transferor] owes to the IRS (including section 6601 interest accruing on [the transferor's] tax debt), up to the limit of the amount transferred to [the transferee], with any recovery of prejudgment interest above the amount transferred to be determined in accord with [state] law.”
1 later decision quote this exact passage · from the majority“Federal interest on a tax obligation accrues automatically ... [and] is simply a part of the debt owed by the taxpayer-transferor to the IRS, see § 6601(e), all of which may usually be collected from a fraudulent transferee to the extent of the amount fraudulently transferred.”
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.