Kuzmick v. Commissioner
United States Tax Court
Over a period of years the taxpayer, assisted by his wife, conducted hundreds of experiments for the improvement of abrasive wheels in the basement of his home. His wife, following instructions during the day, precisely weighed, mixed, and heated ingredients, producing plugs on which both experimented at night after his return from work. Having developed formulae for three types of wheels, the taxpayer applied for patents, which were eventually granted.
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Over a period of years the taxpayer, assisted by his wife, conducted hundreds of experiments for the improvement of abrasive wheels in the basement of his home. His wife, following instructions during the day, precisely weighed, mixed, and heated ingredients, producing plugs on which both experimented at night after his return from work. Having developed formulae for three types of wheels, the taxpayer applied for patents, which were eventually granted. He assigned all interest in these inventions to a manufacturer, which agreed to pay him a percentage of its profits from the sale of wheels…
1Opinion of the Court
Paul L. Kuzmick, Petitioner, v. Commissioner of Internal Revenue, Respondent
Kuzmick v. Commissioner
Docket No. 12887
United States Tax Court
11 T.C. 288; 1948 U.S. Tax Ct. LEXIS 90;
September 16, 1948, Promulgated
Decision will be entered under Rule 50.
Over a period of years the taxpayer, assisted by his wife, conducted hundreds of experiments for the improvement of abrasive wheels in the basement of his home. His wife, following instructions during the day, precisely weighed, mixed, and heated ingredients, producing plugs on which both experimented at night after his return from work. Having…
2Cases cited10 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Dreymann v. Comm'rUnited States Tax Court · 1948
- Zukaitis v. CommissionerUnited States Tax Court · 1944
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