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Commissioner Vs. Sunnen
Cites for this judgment
- US Supreme Court
- Apr 05, 1948
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U.S. 591 (1948) U.S. Supreme Court Commissioner v. SunnenSearch
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U.S. 591 (1948) Commissioner of Internal Revenue v. SunnenSearch
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the same facts, issues and parties but different tax years and made prior to the decisions of this Court in Helvering v. CliffordSearch
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Tower, 327 U. S. 280 , and Lusthaus v. CommissionerSearch
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thereon have not been refunded. Page 333 U. S. 596 Relying upon its own prior decision in Estate of Dodson v. CommissionerSearch
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Cromwell v. CountySearch
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of Sac, supra, 94 U. S. 353 . And see Russell v. PlaceSearch
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Mercoid Corp. v. Mid-ContinentSearch
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Tait v. WesternSearch
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laws, discriminatory distinctions in tax liability, and a fertile basis for litigious confusion. Compare United States v. StoneSearch
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decided in the first proceeding, and where the controlling facts and applicable legal rules remain unchanged. Tait v. WesternSearch
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from those raised in the second case, collateral estoppel has no bearing on the situation. See Travelers Ins. Co. v. CommissionerSearch
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the time of the first judgment and the second, the prior determination is not conclusive. See State Farm Ins. Co. v. DuelSearch
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As demonstrated by Blair v. CommissionerSearch
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the supervening decision cannot justly be ignored by blind reliance upon the rule of collateral estoppel. Henricksen v. SewardSearch
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Pelham Hall Co. v. HassettSearch
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Commissioner v. Arundel-BrooksSearch
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Corrigan v. CommissionerSearch
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Page 333 U. S. 601 and see West Coast Life Ins. Co. v. MercedSearch
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Commissioner v. WesternSearch
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in the pertinent statutory provisions or Treasury regulations can make the use of that rule unwarranted. Tait v. WesternSearch
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bound by that determination in a subsequent proceeding even though the cause of action is different. See Evergreens v. NunanSearch
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or documents and the same bundle of legal principles that contributed to the rendering of the first judgment. Tait v. WesternSearch
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in issue, however similar or identical it may be. In this respect, the instant case thus differs vitally from Tait v. WesternSearch
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the error of the Board's conclusion in the earlier proceeding, thus creating a situation like that involved in Blair v. CommissionerSearch
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supra. This change in the legal picture is said to have been brought about by such cases as Helvering v. PageSearch
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U. S. 280 , and Lusthaus v. CommissionerSearch
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mere assignment of the right to receive income is not enough to insulate the assignor from income tax liability. Lucas v. EarlSearch
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the income to make it reasonable to treat him as the recipient of the income for tax purposes. As was said in Corliss v. BowersSearch
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where the assignee's realization of income depends upon the future rendition of services by the assignor. See Lucas v. EarlSearch
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the receipt of income by the assignee merely being the fruition of the assignor's economic gain. In Harrison v. SchaffnerSearch
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U.S. at 312 U. S. 583 . Commissioner v. TowerSearch
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supra, and its companion case, Lusthaus v. CommissionerSearch
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decision is to be respected on appeal if firmly grounded in the evidence and if consistent with the law. Commissioner v. ScottishSearch
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said that the taxpayer retained the substance of all the rights which he had prior to the assignments. See Helvering v. CliffordSearch
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on substantial evidence and is consistent with the law, and would affirm that judgment for reasons stated in Dobson v. CommissionerSearch
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U. S. 489 , and Commissioner v. ScottishSearch
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Henricksen v. SewardSearch
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Monteith Bros. Co. v. UnitedSearch
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U.S. Supreme Court Commissioner v. SunnenSearch
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Commissioner of Internal Revenue v. SunnenSearch
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Helvering v. CliffordSearch
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and Lusthaus v. CommissionerSearch
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