Gowen v. Commissioner of Internal Revenue

HICKENLOOPER, Circuit Judge.

During the year 1911 petitioner became interested in a patented gas refrigeration machine for domestic use. He caused the leeless Refrigerator Company and the Ice-less Refrigeration Company to be incorporated. The former owned the patents, and the latter manufactured the machines. In 1912 both companies were combined under the name of the Iceless Refrigeration Company, and in 1915 the leeless Machine Company was incorporated to take over the assets and business of the Refrigeration Company. As a result of his investments from time to time in the several…