Civil Procedure Keyed to Cound
Commissioner of Internal Revenue v. Sunnen
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The Taxpayer issued a license on his patents to a corporation, which, in turn gave him a 10% royalty on the licenses. The Taxpayer assigned his right to the royalties to his wife without consideration. She paid the taxes on the royalties as part of her income, but the Taxpayer did not include the royalties on his taxes. The IRS contended that the royalty amounts were taxable to the Taxpayer. The Tax Court held that the royalties from 1937- 1941 were taxable to the Taxpayer except for the royalties paid in the amount of $4,881.35 in 1937 under the 1928 agreement. The Court reached this conclusion because in a prior 1935 proceeding, by the Board of Tax Appeals (the Board) for Taxpayer’s tax liability for 1929 – 1931, the Board held the Taxpayer was not taxable for royalties paid to his wife under the 1928 licensing agreement. The Tax Court held that res judicata barred the court from hearing the claim on the royalties paid in 1937 under that agreement. The Eighth Circuit Court of Appeals affirmed the Tax Court’s holding of res judicata as to payment of 1937 royalties under the 1928 agreement. The Appeals Court reversed the part that held the Taxpayer liable for the royalty amount paid to his wife from 1937-1941.
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