Prepare a case brief for Securities and Exchange Commission v$.$ Howey Co$.,382$ U$.$S$.293(1946).$ You can use the Westlaw database to find the case.

After you have briefed the case, Explain the importance of the SEC v$.$ Howey. How might the case be applied to cryptocurrency? Given the IRS's position on the tax treatment of cryptocurrency in Notice $2014-21,$ how might Howey be used to argue against that position?