SmartBrief
0
Confirm favorite deletion?
Income Tax Keyed to Lind
Watkins v. Commissioner
Citation:
447 F.3d 1269 (10th Cir. 2006)Facts
In 1993, Appellant won $12,358,688 from a lottery ticket he purchased for one dollar. His winning were to be distributed in twenty-five annual installments through an annuity purchased by the Colorado State Lottery. Appellant reported the receipt of his first six prize payments as ordinary income on his federal tax returns.
In 1998, Appellant entered into a contract with Stone Street Capital, Inc. (Stone Street), assign it his remaining lottery payments in exchange for a lump sum payment. On his 1998 tax return, Mr. Appellant reported that the lump sum as proceeding from the sale of a capital asset worth $2,414,744 with a cost basis of zero. Appellee issued a notice of deficiency to Mr. Watkins, claiming the payment he received from Stone Street was ordinary income, not the result of the sale of a capital asset warranting treatment as a capital gain.
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.