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Income Tax Keyed to Lind
Estate of Stranahan v. Commissioner
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*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:
Frank Stranahan, Decedent, entered into a closing agreement with the I.R.S. where he agreed that he owed the I.R.S. $754,815 for interest due to unpaid taxes related to several trusts. He paid the amount in 1964. He accelerated his future income to avoid losing the tax benefit of the interest deduction. In order to do so, he executed an agreement wherein he assigned to his son $122,820 in anticipated stock dividends. His son paid him $115,000 by check in consideration. Decedent reported this amount as income. During the tax year in question, dividends of $40,050 were paid to his son. Decedent’s son reported this as income but Decedent did not. The Commissioner of Internal Revenue sent Decedent’s estate, Appellant, a deficiency notice claiming that the dividend was income to the Decedent. The Tax Court found that the assignment was in reality a loan.
- 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.
- The Brief Prologue closes the case brief with important forward-looking discussion and includes:
- Policy: Identifies the Policy if any that has been established by the case.
- Court Direction: Shares where the Court went from here for this case.