Davis v. United States’s Empirical Analysis
961 F.2d 867 · 1992
Citation profile
34 federal appellate · 6 district · 1 state decisions
How this case has been cited
Cited by 91 later decisions — most recently August 2023 · most notably United States v. Rem (1994), Purcell v. United States (1993)
34 federal appellate · 6 district · 1 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. § 3102 (Federal Insurance Contributions Act) · 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6323 · 26 U.S.C. § 6671 · 26 U.S.C. § 6672 · 26 U.S.C. § 7202 · 26 U.S.C. § 7501
Relies on Atlantic Richfield Co. v. Newman Oil Co. · Burnet v. Harmel · Flora v. United States · Ohio v. Kentucky · Slodov 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 91 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“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 ... 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.”
7 later decisions quote this exact passage · from the majority“voluntary, conscious and intentional act to prefer other creditors over the United States.”
6 later decisions quote this exact passage · from the majority“acted willfully in failing to collect or pay over * * * withheld taxes.”
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.