Agley v. Tracy’s Empirical Analysis
1999
Citation profile
30 state decisions
How this case has been cited
Cited by 30 later decisions — most recently December 2019 · most notably Corrigan v. Testa (Slip Opinion) (2016), Tetlak v. Village of Bratenahl (2001)
30 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Quill Corporation v. North Dakota Heitkamp · Northwestern States Portland Cement Co. v. Minnesota · Miller Bros. v. Maryland · Wisconsin Department of Revenue v. William Wrigley, Jr., Co. · Heublein, Inc. v. South Carolina Tax Commission
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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Appellants also argue that taxation of nonresident shareholders of an S corporation violates their due process rights.... The Due Process Clause ‘requires some definite link, some minimum connection, between a state and the person, property or transaction it seeks to tax.’ Miller Bros. Co. v. Maryland (1954), 347 U.S. 340, 344-345 .... In other words, a state must have minimum contacts with the entity in order to tax it. ... [[Image here]] “Appellants have admitted that their S corporations conducted business in Ohio. Thus, it is evident that the S corporations have utilized the protections and benefits of Ohio by carrying on business here. This income was then passed through to the appellants as personal income. Thus, the appellants, through their S corporations, have also availed themselves of Ohio’s benefits, protections, and opportunities by earning income in Ohio through their respective S corporations. We find that this provides Ohio the ‘minimum contacts’ with the appellants to justify taxing appellants on their distributive share of income.””
2 later decisions quote this exact passage“A corporation is an entity separate and apart from the individuals who compose it; it is a legal fiction for the purpose of doing business [emphasis sic]”
2 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.