Babb v. Frank’s Empirical Analysis

Citation profile

2 federal appellate · 1 district ·

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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “An owner’s right to redeem property seized by the United Stated for failure to pay taxes was well-established long before the passage of 26 U.S.C. § 6337 . See Corbett v. Nutt, 77 U.S. (10 Wall.) 464, 19 L.Ed. 976 (1870); Bennett v. Hunter, 76 U.S. (9 Wall.) 326, 19 L.Ed. 672 (1869). Leniency to the owner in the exercise of this right has always been the rule of thumb. See Corbett, 77 U.S. at 474-75 (“It is the general rule of courts to give to statutes authorizing redemption from tax sales a construction favorable to owners.... ”).”

   2 later decisions quote this exact passage · from the majority
   e.g. Westland Holdings, Inc. v. Lay · 392 F. Supp. 2d 1283 - Westland Holdings, Inc. v. Lay

2. “§ 6339. Legal effect of certificate of sale of personal property and deed of real property (b)Deed of real property. — In the case of the sale of real property pursuant to section 6335— (1) Deed as evidence. — The deed of sale given pursuant to section 6338 shall be prima facie evidence of the facts therein stated; and (2) Deed as conveyance of title. — -If the proceedings of the Secretary as set forth have been substantially in accordance with the provisions of law, such deed shall be considered and operate as a conveyance of all the right, title, and interest the party delinquent had in and to the real property thus sold at the time the lien of the United States attached thereto. (c) Effect of junior encumbrances. — A certificate of sale of personal property given or a deed to real property executed pursuant to section 6338 shall discharge such property from all liens, encumbrances, and titles over which the Ken of the United States with respect to which the levy was made had priority. (d) Cross references.— (1) For distribution of surplus proceeds, see section 6342(b). (2) For judicial procedure with respect to surplus proceeds, see section 7426(a)(2).”

   1 later decision quote this exact passage · from the majority
   e.g. Audio Investments v. Robertson