Legal Opinion
Lyon, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided April 13, 1942No. 8994PublishedCited by 5 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
The ultimate question to be .decided in this "review is whether the respondent correctly determined the basis for depreciation of patents owned by the petitioning taxpayer. This depends .upon whether the taxpayer acquired the patents in pursuance of a reorganization. • If it did, the proper -base is $56,411.90, the cost of the patents to the-transferrer. If it did not, the base is $1,146,201.21, which was the fair market value of the patent applications at the time of their transfer.- Deficiencies were determined in income taxes for the years 1934 to 1937, inclusive, by…
2Cases cited7 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Helvering v. GregoryCourt of Appeals for the Second Circuit · 1934
- Commissioner of Internal Revenue v. Ashland Oil & Refining Co.Court of Appeals for the Sixth Circuit · 1938
- United States v. John Barth Co.Supreme Court of the United States · 1929
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3Cited by5 opinions
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
- Survaunt v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1947
- Pridemark, Inc. v. CommissionerUnited States Tax Court · 1964
- Georgia Properties Co. v. HensleeDistrict Court, M.D. Tennessee · 1955
- Pridemark, Inc. v. CommissionerUnited States Tax Court · 1964