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Business Organizations Keyed to Sjostrom
Watson v. Commissioner
Citation:668 F.3d 1008 (8th Cir. 2012)
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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 1982, David Watson graduated from college with a bachelor’s degree. In 1983, Watson became a Certified Public Account (CPA) and later obtained a master’s degree in taxation. After leaving Earnest & Young, Watson obtained a 25% interest in an accounting firm known as Larson, Watson, Bartling & Eastman. He testified that he received no salary when the firm first began operations. Eventually, the firm reemerged as Larson, Watson, Bartling & Juffer, LLP (LWBJ). In 1996, Watson incorporated a business entity known as David E. Watson, P.C. Watson transferred his individual 25% interest in LWBJ to DEWPC, and thereafter DEWPC replaced Watson as a partner in LWBJ. Watson served as DEWPC’s sole officer, shareholder, director and employee. In 2002 and 2003, DEWPC distributed $24,000 to Watson as employment compensation. In addition to salary, Watson, through DEWPC, received $203,651 from LWBJ as profit distributions for 2002. The Internal Revenue Service investigated DEWPC and determined that it underpaid certain employment taxes pursuant to FICA. On April, 2007, DEWPC paid the delinquent tax, penalty and interest and sought a refund from the IRS, which refused to pay.
- 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.