Legal Opinion

Ransburg Corp. v. Commissioner

United States Tax Court

Decided May 9, 1979No. Docket No. 4569-77Published

Petitioner, a corporation which was not a "holder" as defined in sec. 1235(b), I.R.C. 1954, received payments during the years in issue from the sale of its Japanese patents, patent and utility model applications, and trademarks. The sales contract did not contain any stated interest or specify what portion of the deferred annual payments constituted interest. Petitioner reported the annual payments received as long-term capital gain.

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Petitioner, a corporation which was not a "holder" as defined in sec. 1235(b), I.R.C. 1954, received payments during the years in issue from the sale of its Japanese patents, patent and utility model applications, and trademarks. The sales contract did not contain any stated interest or specify what portion of the deferred annual payments constituted interest. Petitioner reported the annual payments received as long-term capital gain. Respondent determined that a portion of each payment represented unstated interest under sec. 483(a) and was taxable as ordinary income. Held: The payments do…

1Opinion of the Court

Ransburg Corporation and Subsidiaries, Petitioners v. Commissioner of Internal Revenue, Respondent

Ransburg Corp. v. Commissioner

Docket No. 4569-77

United States Tax Court

72 T.C. 271; 1979 U.S. Tax Ct. LEXIS 123;

May 9, 1979, Filed

Decision will be entered under Rule 155.

Petitioner, a corporation which was not a "holder" as defined in sec. 1235(b), I.R.C. 1954, received payments during the years in issue from the sale of its Japanese patents, patent and utility model applications, and trademarks. The sales contract did not contain any stated interest or specify what portion of the deferred annual…

2Cases cited8 opinions

  1. Lusthaus v. CommissionerSupreme Court of the United States · 1946
  2. Hellmich v. HellmanSupreme Court of the United States · 1928
  3. Curtis T. Busse and Myrtle Busse v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
  4. Busse v. CommissionerUnited States Tax Court · 1972
  5. Paxton v. CommissionerUnited States Tax Court · 1969

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