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Citation: 333 U.S. 591

1. Commissioner v. Sunnen, No. 227, SUPREME COURT OF THE UNITED STATES, December 17, 1947, Argued , April 5, 1948, Decided

OVERVIEW: Collateral estoppel should not have been applied to perpetuate the viewpoint of an assignment because as long as the taxpayer, as the assignor, was the source of the right to receive and enjoy the income, he remained taxable.


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