Schmidt v. King’s Empirical Analysis
913 F.2d 837 · 1990
Citation profile
23 federal appellate · 5 district ·
How this case has been cited
Cited by 41 later decisions — most recently June 2012 · most notably Lonsdale v. United States (1990), Geiselman v. United States (1992)
23 federal appellate · 5 district ·
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 28 U.S.C. § 2410
Relies on United States v. John Hancock Mutual Life Insurance · Aqua Bar & Lounge, Inc. v. United States Department of Treasury Internal Revenue Service · Falik v. United States · Laino v. United States · Pollack 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“real or personal property on which the United States has or claims a mortgage or other lien.”
4 later decisions quote this exact passage · from the majoritye.g. Kulawy v. United States · James E. Guthrie Beatrice M. Guthrie v. K.J. Sawyer, District Director Gary L. Collins, Chief, Special Procedures v. Regan, Chief, Collection Division Karen Babcock, Internal Revenue Officer Commissioner of the Internal Revenue Service Internal Revenue Service, and United States of America, Wayne E. Wells Dorothy R. Wells v. K.J. Sawyer, District Director Gary L. Collins, Chief, Special Procedures v. Regan, Chief, Collection Division Karen Babcock, Internal Revenue Officer Commissioner of the Internal Revenue Service Internal Revenue Service, and United States of America“When the taxpayer challenges the procedural regularity of the tax lien and the procedures used to enforce the lien, and not the validity of the tax assessment, sovereign immunity is waived and the district court does have jurisdiction over a quiet title action.”
3 later decisions quote this exact passage · from the majoritye.g. No. 90-2113 · James E. Guthrie Beatrice M. Guthrie v. K.J. Sawyer, District Director Gary L. Collins, Chief, Special Procedures v. Regan, Chief, Collection Division Karen Babcock, Internal Revenue Officer Commissioner of the Internal Revenue Service Internal Revenue Service, and United States of America, Wayne E. Wells Dorothy R. Wells v. K.J. Sawyer, District Director Gary L. Collins, Chief, Special Procedures v. Regan, Chief, Collection Division Karen Babcock, Internal Revenue Officer Commissioner of the Internal Revenue Service Internal Revenue Service, and United States of America“[s]ection 2410 does not extend to challenges for procedural irregularities in assessment or collection of taxes.”
2 later decisions quote this exact passage · from the majoritye.g. James E. Guthrie Beatrice M. Guthrie v. K.J. Sawyer, District Director Gary L. Collins, Chief, Special Procedures v. Regan, Chief, Collection Division Karen Babcock, Internal Revenue Officer Commissioner of the Internal Revenue Service Internal Revenue Service, and United States of America, Wayne E. Wells Dorothy R. Wells v. K.J. Sawyer, District Director Gary L. Collins, Chief, Special Procedures v. Regan, Chief, Collection Division Karen Babcock, Internal Revenue Officer Commissioner of the Internal Revenue Service Internal Revenue Service, and United States of America · Guthrie
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.