Wright v. United States’s Empirical Analysis
809 F.2d 425 · 1987
Citation profile
57 federal appellate · 2 district · 4 state decisions
How this case has been cited
Cited by 117 later decisions — most recently December 2017 · most notably Levit Vn v. Ingersoll Rand Financial Corporation (1989), United States v. McCombs (1994)
57 federal appellate · 2 district · 4 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. § 6672
Relies on Duckworth v. Franzen · United States v. Carroll Towing Co. · Howard v. United States · Mucha v. King
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 117 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'(1) clearly ought to have known that (2) there was a grave risk that withholding taxes were not being paid and if (3) he was in a position to find out for certain very easily.'”
13 later decisions quote this exact passage · from the majority“[I]f a responsible officer [which plaintiff was not] knows that the corporation has recently committed such a delinquency and knows that since then its affairs have continued to deteriorate, he runs the risk of being held liable if he fails to take any steps either to ascertain, before signing checks, what the state of the tax withholding account is, or to institute effective financial controls to guard against nonpayment____ It is not enough that he left it all to ... [another officer] without even inquiring from him what steps would be taken to prevent a repetition of the tax delinquency____”
6 later decisions quote this exact passage · from the majority“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.”
4 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.