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Income Tax Keyed to Lind
Engdahl v. Commissioner
Citation:72 T.C. 659 (U.S.T.C. 1979)
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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:
In 1964, Petitioners began operating a horse-breeding business. Petitioners did substantial preparatory work and sought guidance on how to grow their business. They worked 35-55 hours a week on average, building much of the ranch themselves. The couple did not use the horses or the ranch for personal pleasure but intended to make a profit to supplement their income.
Over the years, the business proved to be unprofitable and Petitioners posted a series of losses. Petitioners applied these losses to the husband’s income from his orthodontist practice. In the notice of deficiency, Respondent disallowed these losses and the claimed investment tax credits based on the conclusion that Petitioners’ horse operation was an activity not engaged in for profit.
- 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.