Legal Opinion

McCullough Tool Co. v. Commissioner

United States Tax Court

Decided January 28, 1960No. Docket No. 66616Published

In 1944 and 1947, petitioner became the exclusive licensee under certain patents by agreements, terminable without default only by petitioner upon written notice, and providing for royalty payments computed upon gross receipts. In 1950, petitioner and its licensors executed modification agreements which provided for the unconditional sale of the patents for agreed prices, the payment of which was to be made in installments.

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In 1944 and 1947, petitioner became the exclusive licensee under certain patents by agreements, terminable without default only by petitioner upon written notice, and providing for royalty payments computed upon gross receipts. In 1950, petitioner and its licensors executed modification agreements which provided for the unconditional sale of the patents for agreed prices, the payment of which was to be made in installments. Held, by the execution of the modification agreements, petitioner acquired fixed costs for the patents, susceptible of depreciation. Held, further, the installment…

1Opinion of the Court

McCullough Tool Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

McCullough Tool Co. v. Commissioner

Docket No. 66616

United States Tax Court

33 T.C. 743; 1960 U.S. Tax Ct. LEXIS 220;

January 28, 1960, Filed

Decision will be entered under Rule 50.

In 1944 and 1947, petitioner became the exclusive licensee under certain patents by agreements, terminable without default only by petitioner upon written notice, and providing for royalty payments computed upon gross receipts. In 1950, petitioner and its licensors executed modification agreements which provided for the unconditional…

2Cases cited4 opinions

  1. Myers v. Comm'rUnited States Tax Court · 1946
  2. Journal Publishing Co. v. CommissionerUnited States Tax Court · 1944
  3. C. W. Titus, Inc. v. CommissionerUnited States Board of Tax Appeals · 1936
  4. McCullough Tool Co. v. CommissionerUnited States Tax Court · 1960

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