Civil Procedure Keyed to Friedenthal
Commissioner of Internal Revenue v. Sunnen
Only StudyBuddy Pro offers the complete Case Brief Anatomy*
Access the most important case brief elements for optimal case understanding.
*Case Brief Anatomy includes: Brief Prologue, Complete Case Brief, Brief Epilogue
- The Brief Prologue provides necessary case brief introductory information and includes:
- Topic: Identifies the topic of law and where this case fits within your course outline.
- Parties: Identifies the cast of characters involved in the case.
- Procedural Posture & History: Shares the case history with how lower courts have ruled on the matter.
- Case Key Terms, Acts, Doctrines, etc.: A case specific Legal Term Dictionary.
- Case Doctrines, Acts, Statutes, Amendments and Treatises: Identifies and Defines Legal Authority used in this case.
- The Case Brief is the complete case summarized and authored in the traditional Law School I.R.A.C. format. The Pro case brief includes:
- Brief Facts: A Synopsis of the Facts of the case.
- Rule of Law: Identifies the Legal Principle the Court used in deciding the case.
- Facts: What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case. Review the Facts of this case here:
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.
- Issue(s): Lists the Questions of Law that are raised by the Facts of the case.
- Holding: Shares the Court's answer to the legal questions raised in the issue.
- Concurring / Dissenting Opinions: Includes valuable concurring or dissenting opinions and their key points.
- Reasoning and Analysis: Identifies the chain of argument(s) which led the judges to rule as they did.