Legal Opinion
Birt E. Slater and Eleanor Slater v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided January 31, 1966No. 8093_1PublishedCited by 15 opinions
1Opinion of the Court
MURRAH, Chief Judge.
By this appeal we are asked to review a decision of the Tax Court to the effect that patent royalties received by the taxpayer for 1954-55-56 were ordinary income, not capital gains as contended by the taxpayers.
The question is presented on agreed facts. The husband taxpayer 1 and two others organized Good, Inc., for the purpose of acquiring from a patentee the exclusive right to manufacture, use and sell his patented article. Each of the in-corporators paid in $1,300 in cash and was issued one share of the company’s stock. No other stock was issued. The corporation…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Chamberlin v. CommissionerUnited States Tax Court · 1959
- Estate of Sam Marsack, Deceased, Betty Marsack, Administratrix, and Betty Marsack v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Anthony Campagna and Marie P. Campagna v. United StatesCourt of Appeals for the Second Circuit · 1961
3Cited by15 opinions
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Fred M. Waring and Virginia Waring v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1969
- In the Matter of Charles A. Steen, Debtor. Dick Dimond, Trustee v. United StatesCourt of Appeals for the Ninth Circuit · 1975
- Robert B. Riss and Georgina Riss v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1966
- Dorsey v. CommissionerUnited States Tax Court · 1968
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