Brian v. Gugin’s Empirical Analysis
1994
Citation profile
1 district ·
Relationships
Applies 26 U.S.C. § 6331 · 26 U.S.C. § 7214 · 26 U.S.C. § 7402 · 28 U.S.C. § 1343
Relies on Estelle v. Gamble · Imbler v. Pachtman · United States v. Mitchell · Del Toro v. United States · Gilbert v. J
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 1 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Title 26 U.S.C. § 6331 (a) authorizes the IRS to seize property of any person hable for any tax upon ten days notice. The plaintiffs are incorrect in stating that §§ 6331 and 6321 only apply to the Bureau of Alcohol, Tobacco and Firearms. The statute specifically states that any person may have their property levied upon 26 U.S.C. § 6331 (a) and 6321.... A “levy” by definition is a summary nonjudicial process which provides the IRS with a prompt and convenient method for satisfying delinquent tax claims. Singlton v. U.S., 73-1 USTC, 1972 WL 435 (W.D.Pa.1972). In Maisano. v. Welcher, 940 F.2d 499 (9th Cir.1991), the court specifically interpreted § 6331 and held that § 6331 apphes to all property of any person hable to the IRS. The court also held that the IRS has the option under § 6502 to collect its assessments either by a levy or a court proceeding, and taxpayers do not have the right to a hearing prior to collection efforts by the IRS. Id. at 502.”
1 later decision quote this exact passage
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.