Learning Objectives BRIEFING COURT CASES At the end of this assignment, you will be able to: •Brief a court case •Understand the significance of facts •Appreciate how subtle changes in facts can make...

Learning Objectives

BRIEFING COURT CASES

At the end of this assignment, you will be able to:
•Brief a court case
•Understand the significance of facts
•Appreciate how subtle changes in facts can make a huge difference in the outcome of a legal

proceeding

Assignment

• 
  

  Read theReadingfor P5(Sample Brief) posted on Canvas.

  
  


• 
  

  Read “Common Errors in Tax Research” in the Resources onCanvas.

  
  


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  Prepare and submit case briefsaccording to the instructions below.

  
  

  Instructions

  
  

  Tax researchers have found that the preparation of a case brief—a concise summary of relevant court case—is an invaluable tool, both when returning to a client’s research problem or whenconstructing a research analysis for another client with a similar problem. You may work on this assignment in pairs.

  
  

  •Below are six pairs of court cases preceded by a group of letters.Select the cases that correspond with the first letter of your last name.(You may use the letter for either partner if you are working in pairs.) The cases citations below may or may not be in the correct form. Be sure to look at the Citation Forms document.

  
  

•Obtain the case opinions (use RIA). Write aone-page brief (no more than 1 1⁄2 pages) for each caseand aone-page contrast of the two cases. (A sample brief is posted in the P5 folder.)You will turn in one Word document with each case 1 on the first page, case 2 on the second page and the contrast on the third page.In comparing the cases, notice how a subtle difference in the facts can completely alter the outcome.The comparison should focus on the differencesin the cases. The contrast should be written as a narrative rather than a numbered or bulleted list.

•Please submit the assignment (Case 1, Case 2 and Contrast) as asingleWord document attachment to Assignments by 10:00 p.m. on the due date (refer to the syllabus for the due date.)If you are working in pairs, the team should turn in only one document with the names of both team members included.

•Put your name in the header of your paper in this format: Last name—P5—A302 (or A551)—spring 2021

1. 
   

   (I-M) William T. Heywood, TC Memo 1994-575, and Donald C. Kimbrough, TC Memo (1988-185)