Legal Opinion

Lane-Wells Co. v. Commissioner

United States Board of Tax Appeals

Decided January 31, 1941No. Docket Nos. 99829, 99830Published

1. Amounts constituting 15 percent of the gross receipts of certain corporations from gun perforation of oil wells received by the taxpayer corporation, more than 50 percent of whose stock was owned by not more than 5 individuals, in return for the use of from 85 to 100 of the taxpayer's patents and applications, of which 7 or 8 patents related to gun perforation, held to be "royalties" within section 351(b)(1) of the Revenue Acts of 1934 and 1936 and section 353 of the…

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1. Amounts constituting 15 percent of the gross receipts of certain corporations from gun perforation of oil wells received by the taxpayer corporation, more than 50 percent of whose stock was owned by not more than 5 individuals, in return for the use of from 85 to 100 of the taxpayer's patents and applications, of which 7 or 8 patents related to gun perforation, held to be "royalties" within section 351(b)(1) of the Revenue Acts of 1934 and 1936 and section 353 of the Revenue Act of 1936, as amended by section 1 of the Revenue Act of 1937, and the taxpayer corporation held to be a "personal…

1Opinion of the Court

LANE-WELLS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

TECHNICRAFT ENGINEERING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Lane-Wells Co. v. Commissioner

Docket Nos. 99829, 99830.

United States Board of Tax Appeals

43 B.T.A. 463; 1941 BTA LEXIS 1495;

January 31, 1941, Promulgated

1. Amounts constituting 15 percent of the gross receipts of certain corporations from gun perforation of oil wells received by the taxpayer corporation, more than 50 percent of whose stock was owned by not more than 5 individuals, in return for the use of from 85 to…

2Cases cited21 opinions

  1. Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
  2. Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
  3. Bellport v. HarrisonSupreme Court of Kansas · 1927
  4. Western Union Tel. Co. v. American Bell Tel. Co.Court of Appeals for the First Circuit · 1903
  5. Blenheim Co. v. CommissionerUnited States Board of Tax Appeals · 1940

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