George v. Scent’s Empirical Analysis

Citation profile

1 federal appellate · 37 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[t]axing laws should be plain and precise, for they impose a burden upon the people. That imposition should be explicitly and distinctly revealed. If the Legislature fails so to express its intention and meaning, it is the function of the judiciary to construe the statute strictly and resolve doubts and ambiguities in favor of the taxpayer and against the taxing powers.”

   4 later decisions quote this exact passage
   e.g. Louisville/Jefferson County Metro Government v. Hotels.com, L.P. · Appalachian Racing, LLC v. Family Trust Foundation of Kentucky, Inc.

2. ““It is to be remembered that equality of taxation is the demand of the Constitution. §§ 171, 172, 173. It is a touchstone by which a taxing statute is to be tested. The principal decision in Henneford v. Silas Mason Co., 300 U.S. 577 , 57 S.Ct. 524, 527 , 81 L.Ed. 814 , cited by the parties herein, was that the imposition of the sales and use tax by the State of Washington upon construction machinery and material brought into the state was not a burden upon interstate commerce, for it was levied after the property had come to rest. With reference to the payment of similar taxes on the same property in other states, Mr. Justice Cardozo observed: ‘When the account is made up, the stranger from afar is subject to no greater burdens as a consequence of ownership then the dweller within the gates. The one pays upon one activity or incident, and the other upon another, but the sum is the same when the reckoning is closed. Equality exists when the chattel subjected to the use tax is bought in another state and then carried into Washington.’ ””

   1 later decision quote this exact passage
   e.g. Genex/London, Inc. v. Kentucky Board of Tax Appeals

3. ““... Because of their mobility, the use tax is a justifiable device to protect the revenue and local dealers from outside purchases of automobiles; otherwise, their purchase out of the state would escape payment of the state’s sales tax. Together the two provisions form a comprehensive tax system applicable to the sale of motor vehicles. It is an excise and not a property tax or fee for registration. ... Such statutes ‘normally exempt goods upon which a sales tax has previously been paid.’ 47 Am.Jur., Sales and Use Tax, § 42. This results in equality. Annotations, 129 A.L.R. 223 , 228; 1 A.L.R.2d 453 .””

   1 later decision quote this exact passage
   e.g. Genex/London, Inc. v. Kentucky Board of Tax Appeals