Compañía General de Tabacos de Filipinas v. Collector of Internal Revenue’s Empirical Analysis

Citation profile

65 federal appellate · 3 district · 72 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 243 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Taxes are what we pay for civilized society.”

   16 later decisions quote this exact passage · from the dissent
   e.g. United States v. Zukerman · James E. Redlark and Cheryl L. Redlark v. Commissioner

2. “Taxes are what we pay for civilized society.” Compañía General de Tabacos de Filipinas v. Collector of Internal Revenue, 275 U.S. 87 , 100, 48 S.Ct. 100 , 72 L.Ed. 177 (1927) (Holmes, J., dissenting). 106 T.C. at 71-72 , 1996 WL 10243 (Halpern, J., dissenting); see also id. at 60, 1996 WL 10243 (Ruwe, J., dissenting) (”

   2 later decisions quote this exact passage · from the dissent
   e.g. Kikalos v. Commissioner · Nick Kikalos and Helen Kikalos v. Commissioner of Internal Revenue

3. ““It being established that the relation of the foreign company to domestic poli■cy holders constituted doing business within the meaning of the statute, the question is whether the company may be taxed in respect of it, in this way, whatever it may be called. We are dealing with a corporation that has subjected itself to the jurisdiction of the state; there is no question that the state has a right to tax it, and the only doubt is whether it may take this item into account in fixing the figure of the tax. Obviously the limit in that regard is a different matter from the inquiry whether the residence of a policy holder would of itself give jurisdiction over the company. The argument of the state court is that the company is protecting its insured in Pennsylvania equally whether they pay their premiums - to the company’s agent in Philadelphia or by mail or in person to another in New York. “These are policies of life insurance, and, according to the statement of the plaintiff in error, are kept alive and renewed " to residents of Pennsylvania by payments from year to year. The fact that the state could not prevent the contracts, so far as that may be true, has little bearing upon its right to consider the benefit thus annually extended into Pennsylvania in measuring the value of the privileges that it does grant. We may add that the state profits the company equally by protecting the lives insured, wherever the premiums are paid. The tax is a tax upon a privilege actually used.”

   1 later decision quote this exact passage · from the majority
   e.g. Osborne v. Ozlin