Brady v. State’s Empirical Analysis

Citation profile

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

1. “There is hereby imposed for each taxable year on the taxable income which is derived from sources in this state of every nonresident ... a tax which shall be equal to the tax computed ... as if such nonresident ... were a resident, multiplied by a fraction, the numerator of which is such individual’s ... New York source income ... and the denominator of which is such individual’s ... federal adjusted gross income for the taxable year. [Emphasis added.]”

   2 later decisions quote this exact passage · from the majority
   e.g. Chin v. Director · 14 N.J. Tax 349 - Widder v. Director

2. “[t]he procedure for taxing the New York source income of a nonresident set forth in Tax Law § 601(e), by initially applying a progressive tax rate to the taxpayer’s income from all sources and then apportioning to fix the final tax due, is a valid means, under due process, of using income not itself taxable as part of the measurement of the tax imposed on the nonresident’s New York income. [Brady v. State, 576 N.Y.S.2d at 899 ; emphasis added.]”

   1 later decision quote this exact passage · from the majority
   e.g. Chin v. Director