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Income Tax Keyed to Lind
Alice Phelan Sullivan Corp. v. United States
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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:
Alice Phelan Sullivan Corp (Plaintiff) made two charitable conveyances of parcels in 1939 and 1940. Taxpayer deducted $4,243.49 and $4,463.44 respectively for a combined tax benefit of $1,877.49. In 1957, the donee decided not to use the parcels and reconveyed to Plaintiff. In 1957, Plaintiff did not include the $8,706.93 land value as taxable income. The Commissioner of Internal Revenue, upon audit, determined the amount was taxable income and applied the 52% corporate tax rate to determine Plaintiff was deficient by $4,527.60. Plaintiff paid deficiency and claimed a refund for $2,650.11, the amount of the deficiency in excess of the original tax benefit received by making the charitable contribution.
- 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.