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Income Tax Keyed to Lind
Williams 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:
Petitioners, Mr. and Mrs. Williams, are a husband and wife living in Portland, Oregon. Mr. Williams was in the business of locating marketable parcels of timberland for prospective buyers of timber. He provided information to Lester McConkey and J.M. Housley and received nothing at the time. In 1951 Housley issued to him an unsecured, non-interest bearing promissory note in the amount of $7,166 payable 240 days later. It was understood that Housley would not be able to pay until after he acquired and sold at least part of the timber. Petitioners attempted to sell the note to banks and finance companies and were unsuccessful. They collected $6,666 from Housley in 1954 on the note. Petitioners reported income from the note in 1954 and not in 1951. The Commissioner determined that Petitioners should have reported the note as income in 1951.
- 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.