Aluminum Company of America, and Cross-Appellant v. Department of the Treasury of the State of Michigan, and Cross-Appellees’s Empirical Analysis

Citation profile

16 federal appellate · 2 district ·

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

1. “The committee reports reflect two main purposes and two secondary purposes underlying § 1341. First, the Act is aimed at eliminating the discriminatory effect on State citizens, who are limited to State agencies and courts in settling their State tax disputes, of allowing foreign corporations to take State tax disputes into federal courts as well as allowing them access to State Courts.... The Act’s second main purpose is to eliminate disruption of State financing efforts by foreign corporations. The Senate Report noted it was then common practice * * * for foreign corporations doing business in such States to withhold from them and their governmental subdivisions taxes in such vast amounts and for such long periods of time as to seriously disrupt State and county finances. The pressing needs of these States for this tax money is so great that in many instances they have been compelled to compromise these suits, as a result of which substantial portions of the tax have been lost to the States without a judicial examination into the real merits of the controversy. Insertions in the Congressional Record which accompany the report of discussion of this measure on the floor of the Senate indicate two secondary reasons behind § 1341. The first is a concern that the added expense of litigating in the federal courts might make it financially unsound for the State or a local taxing authority to contest a wealthy corporation’s tax liability. The other is to relieve congestion in the f”

   1 later decision quote this exact passage · from the majority
   e.g. In re Gillis

2. “... we need not decide whether omission to provide interest on a successful refund application renders the state rem edy here an inadequate one within the meaning of § 1341.”

   1 later decision quote this exact passage · from the majority
   e.g. 508 F. Supp. 229 - Bunte Candies, Inc. v. Cartwright

3. “... failure to utilize a remedy does not render that remedy insufficient” under TIA). 23 . The Supreme Court categorizes the TIA as a”

   1 later decision quote this exact passage · from the majority
   e.g. Northbrook Partners LLP v. County of Hennepin (In Re Northbrook Partners LLP)