United States v. Badger’s Empirical Analysis
930 F.2d 754 · 1991
Citation profile
8 federal appellate ·
Relationships
Applies 18 U.S.C. § 3149 (Bail Reform Act of 1984) · 26 U.S.C. § 6331 · 26 U.S.C. § 6343 · 26 U.S.C. § 7421 · 26 U.S.C. § 7426
Relies on Cohen v. Beneficial Industrial Loan Corp. · Mistretta v. United States · Vandygriff v. Phillips · Hannahville Indian Community v. United States · United States v. McConney
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“I.R.C. § 6331 provides for a lien on “all property and rights to property” belonging to the delinquent taxpayer. There is no exception for bail bonds. Moreover, there is no requirement that the IRS prove that any portion of property being levied upon belongs to the delinquent taxpayer before it can levy on the property. Under I.R.C. § 7421(a), the Anti-Injunction Act [footnote omitted], if any person wishes to contest the levy, that person must bring a wrongful levy action under I.R.C. § 7426 or other provisions specified in the Anti-Injunction Act. These I.R.C. sections indicate that the district court was required to honor the IRS’s levy without inquiring into its validity or determining how much of the bail bond belongs to Badger.”
1 later decision quote this exact passage · from the majority“to decide competing claims to [a bail] bond”
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.