Encyclopedia Britannica v. Commissioner

685 F.2d 212 (1982)

From our private database of 46,300+ case briefs, written and edited by humans—never with AI.

Encyclopedia Britannica v. Commissioner

United States Court of Appeals for the Seventh Circuit
685 F.2d 212 (1982)

Play video

Facts

Encyclopedia Britannica (Britannica) (plaintiff) decided to publish a book entitled The Dictionary of Natural Sciences. Ordinarily, Britannica would research, author, edit, and publish the book, as it was in the business of doing so. However, Britannica was short-staffed and hired David-Stewart Publishing Company (David-Stewart) to prepare the manuscript under the supervision of Britannica’s editorial staff. Britannica paid David-Stewart an advance against the royalties that Britannica expected to receive on the book. On its federal tax return, Britannica deducted the advance payment to David-Stewart as a business expense. The federal tax commissioner (commissioner) (defendant) disallowed the deduction and assessed deficiencies against Britannica. Britannica petitioned the United States Tax Court for a redetermination. The tax court entered judgment in favor of Britannica, and the commissioner appealed to the United States Court of Appeals for the Seventh Circuit.

Rule of Law

Issue

Holding and Reasoning (Posner, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 815,000 law students since 2011. Some law schools even subscribe directly to Quimbee for all their law students.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

Here's why 815,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 815,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,300 briefs - keyed to 988 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership