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Civil Procedure Keyed to Babcock
Commissioner of Internal Revenue v. Sunnen
Citation:333 U.S. 591 (1948)
Between 1937–1941 Defendant Sunnen gifted his wife patent-license contracts to avoid paying income taxes on the royalties. The IRS sued Defendant claiming the royalties were taxable as income. The court, using res judicata, concluded that Sunnen could be taxed for all the royalties except for the royalties paid in 1937 on a 1928 contract based on a prior ruling by the Board of Tax Appeals that disallowed collection of taxes on royalties received between 1929–1931 on a 1928 contract. The United States Court of Appeals for the Eighth Circuit affirmed and the Supreme Court granted certiorari.
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