Inn Group Associates v. Booth’s Empirical Analysis

Citation profile

6 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[m]indful of th[e] [Supreme] [C]ourt’s mandate that ‘taxing statutes are to be strictly construed’ with doubts resolved in favor of the taxpayer.... ‘Assessment proper includes valuation but valuation alone is not the assessment but instead only its most important element.’ 3 Cooley, The Law of Taxation § 1044 at 2114 (4th ed. 1924).... [T]he term ‘assessment’ as used in our taxing statutes carries with it a variety of meanings and noting also the statutory language before us, to wit, ‘[a]ny person aggrieved on any ground whatsoever by any assessment of taxes ...,’ we have no hesitancy in holding that within the context of [R.I.G.L.] § 44-5-26 the term ‘assessment’ refers to the entire plan or statutory scheme for the imposition and collection of taxes, including the calculation of the rate.”

   1 later decision quote this exact passage
   e.g. Capital Properties, Inc. v. State

2. “[d]oubts as to the construction of [taxing] laws * * * are to be resolved in favor of the taxpayer”

   1 later decision quote this exact passage
   e.g. Michael A. Balmuth v. David E. Dolce, in his capacity as Tax Assessor for the Town of Portsmouth John Qua v. David E. Dolce William Antle v. David E. Dolce