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Income Tax Keyed to Lind
Cowden 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 Cowden, Sr. and his wife made an oil, gas, and mineral lease for them and their children on land in Texas to Stanolind Oil and Gas Company. Stanolind agreed to make supplemental bonus or advance royalty payments of $511,192.50. The payments were a definitive obligation regardless of the production on the lease, and were to be made over several years and not all at once. The Cowdens assigned the payments to First National Bank of Midland for face value less a small discount. The Cowdens reported the amounts received from the assignment as long-term capital gains. The Commissioner of Internal Revenue found that the Cowdens should have been taxed on the full amount regardless of the deferred payment arrangements because they were equivalent to cash.
- 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.