MacCallum Gauge Co. v. Commissioner
United States Board of Tax Appeals
Upon the evidence, held that a patent was owned by one individual instead of two and that since immediately after the exchange of the patent to the petitioner for stock, such individual was not in control of the petitioner, this proceeding is governed by the general provision that the basis for the determination of the deduction for exhaustion allowance on the patent is the cost of such patent to the petitioner.
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Upon the evidence, held that a patent was owned by one individual instead of two and that since immediately after the exchange of the patent to the petitioner for stock, such individual was not in control of the petitioner, this proceeding is governed by the general provision that the basis for the determination of the deduction for exhaustion allowance on the patent is the cost of such patent to the petitioner. Held, further, that the cost of the patent is measured by the fair market value of the stock issued therefor. which, upon the evidence, is determined.
1Opinion of the Court
MACCALLUM GAUGE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MacCallum Gauge Co. v. Commissioner
Docket No. 70437.
United States Board of Tax Appeals
32 B.T.A. 544; 1935 BTA LEXIS 936;
April 30, 1935, Promulgated
Upon the evidence, held that a patent was owned by one individual instead of two and that since immediately after the exchange of the patent to the petitioner for stock, such individual was not in control of the petitioner, this proceeding is governed by the general provision that the basis for the determination of the deduction for exhaustion allowance on the…
2Cases cited7 opinions
- Pierce Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1935
- McKinney v. CommissionerUnited States Board of Tax Appeals · 1935
- Mead Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- John Glackner Realty Corp. v. CommissionerUnited States Board of Tax Appeals · 1928
- MacCallum Gauge Co. v. CommissionerUnited States Board of Tax Appeals · 1935
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