Wright v. Georgia Railroad & Banking Co.’s Empirical Analysis

Citation profile

49 federal appellate · 7 district · 18 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 140 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““By the original charter of the Georgia Railroad and Banking Company it was, in terms, provided that ‘the stock of said company and its branches, shall be exempt from taxation for seven years from the completion of said railroads, or any one of them, and after that, shall be subject to a tax of not exceeding one-half of one per cent, per annum on the net proceeds of their investments “Held, that under the settled rules of construction, it was competent for the legislature to grant this exemption, and forming, as it does, a portion of the contract of incorporation, any repeal of it by the legislature, without the consent of the corporation, is in violation of article 1, section 10, paragraph 1 of the constitution of the United States prohibiting any state from passing any law impairing the obligation of contracts.””

   1 later decision quote this exact passage · from the majority
   e.g. Georgia Railroad & Banking Co. v. Redwine

2. “* * * A tax upon earnings is a tax which at least covers and includes, unless double taxation is intended, all property necessarily held and used to make that income, including the enjoyment of its franchises. * * * * * * * * *Page 105 "If we are right in construing the tax as one upon net income as a substitute for a property tax, the franchise may no more be taxed than any other property appropriate to the operation of the road. When the State gave up the right to levy and collect a property tax and to take in substitution a tax upon the annual net profit, it gave up the right to tax the franchise of the company as certainly as it gave up the right to tax its railroad.”

   1 later decision quote this exact passage · from the majority
   e.g. The Pullman Co. v. Commissioner of Taxation

3. “There is an obvious distinction between the capital stock of an incorporated, company and the “shares” of the company. The one is the capital upon which the business is to be undertaken, and is represented by the property of every kind acquired by the company. Shares are the mere certificates which represent a subscriber’s contribution to the capital stock and measure his interest in the company.”

   1 later decision quote this exact passage · from the majority
   e.g. Anderson-Clayton Sec. Corp. v. Commissioner