SmartBrief
Confirm favorite deletion?
Constitutional Law Keyed to Levinson
Moore v. United States
Citation:
602 U.S. 572 (2024)Facts
In 2006, Charles and Kathleen Moore invested $40,000 in KisanKraft, an American-controlled foreign corporation founded by one of their friends to supply farm equipment in India. In exchange for their investment, the Moores received a 13-percent ownership share in the company. Between 2006 and 2017, KisanKraft generated substantial income from its business operations in India. However, the corporation never declared dividends or distributed any of its profits to its American shareholders, including the Moores. As a result, neither KisanKraft nor the Moores had paid U.S. taxes on that accumulated income. When the Tax Cuts and Jobs Act of 2017 was enacted, it included the Mandatory Repatriation Tax (MRT), which imposed a one-time tax on American shareholders of American-controlled foreign corporations based on their pro rata shares of the corporations’ accumulated undistributed income. The MRT applied to the Moores because of their investment in KisanKraft. By the end of the 2017 tax year, the Moores’ pro rata share of KisanKraft’s accumulated income from 2006 to 2017 totaled approximately $508,000. After applying a statutory deduction, the Moores declared $132,512 in income under the MRT, resulting in a tax liability of $14,729. The Moores paid this amount but then sued for a refund, arguing that the MRT was unconstitutional.
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.
Topic Resources
14m 29sTopic Outline 
Topic Refresher Course 
Topic Charts & Notes 