United States v. Huckabee Auto Co.’s Empirical Analysis
783 F.2d 1546 · 1986
Citation profile
32 federal appellate · 7 district · 2 state decisions
How this case has been cited
Cited by 123 later decisions — most recently July 2018 · most notably Michigan Employment Security Commission v. Wolverine Radio Co. (1991), United States v. Technical Knockout Graphics, Inc. (1987)
32 federal appellate · 7 district · 2 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 11 U.S.C. § 1129 · 26 U.S.C. § 3102 (Federal Insurance Contributions Act) · 26 U.S.C. § 3402 · 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6671 · 26 U.S.C. § 6672 · 26 U.S.C. § 7421 · 26 U.S.C. § 7501
Relies on Bonner v. City of Prichard · Richardson v. Hynson, Westcott & Dunning, Inc. · Interstate Circuit, Inc. v. City of Dallas · Universal Builders, Inc. v. Clark · United States v. Sotelo
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 123 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, in addition to other penalties provided by law, be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over.”
11 later decisions quote this exact passage · from the majority“[t]he jurisdiction of the bankruptcy courts encompasses determinations of the tax liabilities of debtors who file petitions for relief under the bankruptcy laws. It does not, however, extend to the separate liabilities of taxpayers who are not debtors under the Bankruptcy Code.”
9 later decisions quote this exact passage · from the majority“(a) Penalty assessed as tax. — The penalties and liabilities provided by this subchapter shall be paid upon notice and demand by the Secretary, and shall be assessed and collected in the same manner as taxes. Except as otherwise provided, any reference in this title to "tax" imposed by this title shall be deemed also to refer to the penalties and liabilities provided by this subchapter. (b) Person defined. — The term “person”, as used in this subchapter, includes an officer or employee of a corporation, or a member or employee of a partnership, who as such officer, employee, or member is under a duty to perform the act in respect of which the violation occurs.”
2 later decisions 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.