Questions on US Supreme Court Cases

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Question 1 Morrissey v Commissioner of Internal Revenue was a U.S. Supreme Court case decided in 1935. The case revolved around tax rulings, deficiencies, and valuations and the burden of proof on such. Essentially, the Internal Revenue Code defines a corporation to include associations, insurance companies, and joint-stock companies. Prior to the Supreme Court ruling the IRS identified certain criteria that distinguished what a corporation was legally and how it differed from an Association. In Morrissey, the trustees of an express trust, contested income taxes for the years 1924 to 1926 upon the grounds that it had been illegally treated as an association. The Tax board sustained the ruling of the Commissioner of the IRS and the Circuit Court of Appeals affirmed all decisions. The association was a collective "Golf Club" in Los Angeles in which trustees were given certificates and rights for surplus, profits, and capital assets. The death of a trustee or a beneficiary was not to end the trust, which would continue for at least 25 years. However, during the 1921-23 periods, the trustees sold beneficial interests and paid commission on sales of property, etc. After January 12, 1924, however, the petitioner's activities were limited to collections of installments of principal and interest on notes, receipts of interest from bank accounts, and fees. The petitioners thus believed they were trustees only and not taxable as an association or a corporation. Based on the 1924 Tax
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