Sanchez v. Comm'r
United States Tax Court
1. Petitioner, a nonresident alien individual, invented a process for refining sugar which involved the use of a chemical called Sucro-Blanc. He assigned all his rights to the invention and patents to a New York corporation, which transferred its rights to another New York corporation of which it held control, petitioner holding a smaller amount of stock.
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1. Petitioner, a nonresident alien individual, invented a process for refining sugar which involved the use of a chemical called Sucro-Blanc. He assigned all his rights to the invention and patents to a New York corporation, which transferred its rights to another New York corporation of which it held control, petitioner holding a smaller amount of stock. This corporation executed within the United States licenses for the process without charge, and manufactured in the United States, and sold to such licensees in the United States the product essential to the process. It agreed to pay…
1Opinion of the Court
opinion.
Kern, Judge:
The first issue which we have to decide is whether certain payments, designated as royalties, received by petitioner in 1940 from Sucro-Blanc, Inc., a New York corporation, constituted income from sources within the United States, as respondent contends, or from sources without the United States, as petitioner contends.
Petitioner is the inventor of what we shall call the Sucro-Blanc process for refining sugar, a patent for which, in 1934, had been issued in Cuba, and applied for in the United States, which involves the use of a hypochlorite called Sucro-Blanc. In 1934 he…
2Cited by11 opinions
- Griffith v. CommissionerUnited States Tax Court · 1961
- Cozzens v. CommissionerUnited States Tax Court · 1953
- Estate of Basch v. CommissionerUnited States Tax Court · 1947
- Estate of Snider v. CommissionerUnited States Tax Court · 1962
- Cozzens v. CommissionerUnited States Tax Court · 1953
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