Wake County v. Ingle’s Empirical Analysis

Citation profile

20 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““[T]hat the fact that the church maintains and pays expenses connected with its use of the leased property, which is a church building and its appurtenances on Rhamkatte Road, does not prevent the church from occupying this property gratuitously. It pays no rent for the leased property, and merely maintains and pays the expenses connected with its use of the leased property which it must do to use properly the leased property for religious purposes. If the church had owned this leased property and had used it, it would have had to maintain it and pay the expenses connected with its use as church property. To adopt a contrary construction would mean a narrow and stinting construction of the statute. It is clear that if the church were the owner of this property which it uses wholly and exclusively for religious worship, it would be exempt from taxation. It seems to us, and we so hold, that to hold this property in controversy exempt from taxation pursuant to G.S. 105-296(3) comes clearly within the scope and purpose of the language used in that statute, and it clearly comes within the scope and language of the constitutional provision of Article V, section 5, that property held for religious purposes shall be exempt from taxation. Plaintiffs’ assignments of error are overruled.””

   1 later decision quote this exact passage
   e.g. 45 N.C. App. 632 - Matter of Taxable Status of Property, Etc.

2. ““What is said in Seminary, Inc. v. Wake County, 251 N.C. 775 , 112 S.E. 2d 528 , is relevant here: ‘In this connection this Court stated in Harrison v. Guilford County, 218 N.C. 718 , 12 S.E. 2d 269 , that statutes exempting specific property from taxation because of the purposes for which such property is held and used, are and should be construed strictly, when there is room for construction, against exemption and in favor of taxation (citing cases). ‘ “By the rule of strict construction, however, is not meant that the statute shall be stintingly or even narrowly construed * * * but it means that everything shall be excluded from its operation which does not clearly come within the scope of the language used.” Stacy, C.J., in S. v. Whitehurst, 212 N.C. 300 , 193 S.E. 657 .’ ””

   1 later decision quote this exact passage
   e.g. 45 N.C. App. 632 - Matter of Taxable Status of Property, Etc.