SmartBrief
0
Confirm favorite deletion?
Income Tax Keyed to Graetz
Hallmark Cards, Inc. v. Commissioner
Citation:
90 T.C. 26 (1988)Facts
Petitioner had a policy of shipping its goods to its buyer well in advance of when the goods would be sold. Petitioner’s buyers objected to this practice with Valentine’s Day cards, as they did not wish to hold this type of item in their inventory (as opposed to Christmas cards). Petitioner contracted with its buyers to ship the Valentine’s Day cards to them before the year’s end, but not to transfer title until the following year. This resulted in a deferral of income to the following year for Petitioner, despite the transfer of goods in the year prior, for which the Commissioner of Internal Revenue asserted a tax deficiency.
Only StudyBuddy Pro offers the complete Case Brief Anatomy*
Access the most important case brief elements for optimal case understanding.
*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.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.