Vivigen, Inc. v. Minzner’s Empirical Analysis

Citation profile

11 state decisions

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.

1. “[i]f the taxpayer pays taxes on a transaction under one view of the facts and the law, the government cannot impose taxes on the transaction under a different view of the facts or the law without giving the taxpayer credit for the initial amount paid, even though the taxpayer’s claim for refund or credit would otherwise be untimely-”

   1 later decision quote this exact passage
   e.g. Teco Investments, Inc. v. Taxation & Revenue Department

2. “the Supreme Court has decided 'that a claim of equitable recoupment will lie only where the Government has taxed a single transaction, item, or taxable event under two inconsistent theories.'”

   1 later decision quote this exact passage
   e.g. 230 Wis. 2d 607 - Wisconsin Department of Revenue v. Van Engel

3. “without suggesting that the court was consciously rejecting the doctrine as expressed in that case.”

   1 later decision quote this exact passage
   e.g. 230 Wis. 2d 607 - Wisconsin Department of Revenue v. Van Engel