The purpose of this assignment is to familiarize you with the various tax court cases involving individual and corporate transactions that have been decided at all levels of the United States court system. These cases have often established the precedent for the treatment of certain tax transactions, and serve as a source of tax research. Assigned court cases will reinforce the key concepts learned in class. Students will summarize their choice of the following court cases (or their own selection with pre-approval by the instructor), using the “FICA” model of analysis. FICA stands for Fact, Issue, Conclusion, and Analysis and allows you to concisely summarize the conclusions of a court case. To summarize the case, follow these steps:
- State the facts of the case in a clear and concise matter
- Identify the issue(s)/laws at hand
- State the conclusion of the court
- Complete your analysis of the findings as presented in the case (answer the question: “why did the court rule this way on this issue?”)
Briefs should be at least two pages long, double-spaced, 12-point font.
Sample Court Cases:
Cavaretta v. Comm’r, T.C. Memo 2010-4.
Comm’r v. Indianapolis Power & Light Co., 493 US 203.
Comm’r v. Lincoln Electric Co., 176 F.2d 815
Comm’r v. Sullivan, 356 US 27.
Complete Auto Transit, Inc v. Brady, 430 US 274.
Geoffrey, Inc. v. South Carolina Tax Commission, S.C. Sup. Ct., 313 S.C.
Gregory v. Helvering, 293 US 465.
Indopco v. Comm’r, 503 U.S. 79.
Kerns v. Comm’r, T.C. Memo 2004-63.
Lanco, Inc. v. Director, Division of Taxation, NJ Sup. Ct., Dkt. No. A-89-05.
National Bellas Hess, Inc. v. Department of Revenue of the State of Illinois, 386 US 753.
Northwestern Cement Co. v. Minnesota, 358 US 450.
Quail Corporation v. North Dakota, 504 US 298.
Renkemeyer, Campbell, & Weaver LLP v. Comm’r, 136 T.C. 137.
Retief Goosen v. Comm’r, 136 T.C. No. 27.
Scripto, Inc. v. Carson, Sherriff, et al., 362 US 207.
Tax Comm’r of West Virginia v. MBNA America Bank, 640 SE 2d 226.
U.S. v. Boulware, 558 F.3d 971.
U.S. v. Davis, 397 US 301.
Welch v. Helvering, 290 US 111.
Wisconsin Dept. of Revenue v. William Wrigley, Jr. Co., 505 US 214.