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  • Commissioner of Internal Revenue v. SunnenCommissioner of Internal Revenue v. Sunnen
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Commissioner of Internal Revenue v. Sunnen

United States Supreme Court
333 U.S. 591 (1948)


Between 1937 and 1941, Sunnen (defendant) gave his wife several patent-license contracts as gifts, in order to avoid having the resultant royalties be attributed to him as taxable income. The Internal Revenue Service (IRS) (plaintiff) challenged this gift, arguing that the royalties were taxable income. The Tax Court agreed, except for royalties paid in 1937 on a 1928 contract. The court came to this conclusion based on a previous holding by the Board of Tax Appeals, which stated that the royalties received between 1929 and 1931 on the 1928 contract were not taxable. Applying res judicata, the Tax Court found that Sunnen could not be taxed in 1937 on the 1928 contract. The United States Court of Appeals for the Eight Circuit affirmed, and the United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Murphy, J.)

Dissent (Frankfurter, J.)

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