Stratton v. Jackson’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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In conclusion, Plaintiff “has failed to produce an audit, actual books and records, or summaries thereof, or other evidence to establish that it owes less taxes than the amount assessed by the Department of Revenue. The taxpayer has done no more than to make allegations to the effect that the State’s audit method was incorrect, inapplicable or constitutes only an estimate. ...””

   2 later decisions quote this exact passage
   e.g. Marx v. Bounds · Wylie Steel Fabricators, Inc. v. Johnson

2. “Moreover, this Court will not reward, directly or indirectly, the failure of a person to maintain adequate records of illegal sales of liquor by setting aside an assessment of taxes on such sales because the Commissioner based his tax assessment on an estimate. Not only does evidence support the assessment made by the Commissioner, but Plaintiff has not shown how the method of assessment was erroneous, except to allege that it was not based on any records or other evidence and was therefore arbitrary. ...”

   1 later decision quote this exact passage
   e.g. Marx v. Bounds