International Cigar Mach. Co. v. Commissioner
United States Board of Tax Appeals
Petitioner, who was the owner of patents on cigar making machines, contracted with cigar makers to supply them with the patented machines in consideration of (a) lump sum payments and (b) royalties based on the number of cigars made. The lump sums specified in the contracts were equivalent to the amounts that it would cost to have the machines made by a manufacturing company, the petitioner having no facilities of its own to manufacture the machines.
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Petitioner, who was the owner of patents on cigar making machines, contracted with cigar makers to supply them with the patented machines in consideration of (a) lump sum payments and (b) royalties based on the number of cigars made. The lump sums specified in the contracts were equivalent to the amounts that it would cost to have the machines made by a manufacturing company, the petitioner having no facilities of its own to manufacture the machines. On receipt of lump sums the petitioner deposited them in its regular bank account, but entered them in separate accounts on its books. On…
1Opinion of the Court
INTERNATIONAL CIGAR MACHINERY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
International Cigar Mach. Co. v. Commissioner
Docket Nos. 71331, 76285.
United States Board of Tax Appeals
36 B.T.A. 124; 1937 BTA LEXIS 763;
June 16, 1937, Promulgated
Petitioner, who was the owner of patents on cigar making machines, contracted with cigar makers to supply them with the patented machines in consideration of (a) lump sum payments and (b) royalties based on the number of cigars made. The lump sums specified in the contracts were equivalent to the amounts that it would cost to have the…
2Cases cited8 opinions
- Brown v. HelveringSupreme Court of the United States · 1934
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Taylor v. BucknerCourt of Appeals of Kentucky · 1819
- Morphy v. CommissionerUnited States Board of Tax Appeals · 1937
- Ribbon Cliff Fruit Co. v. CommissionerUnited States Board of Tax Appeals · 1928
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