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Income Tax Keyed to Lind
International Freighting Corporation, Inc. 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:
Taxpayer had an arrangement to pay certain employees bonuses in the form of common stock of the DuPont company. Taxpayer paid over and distributed 150 shares of common stock at a cost of $16,153.36. The market value was $24,858.75. Each of the employees paid a tax on the stock. Taxpayer deducted $24,858.75 in its income tax return. The Commissioner reduced the deduction to $16,153.36 arguing that the basis for determining the amount is the cost of the property and not the fair market value. Before the Tax Court, the Commissioner argued that if Taxpayer were entitled to a deduction in the amount of $24,858, then Taxpayer realized a gain that should be reported as taxable profit. The Tax Court held that the Taxpayer was entitled to the full deduction and that the profit should count as gross income.
- 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.