Computer Sciences Corp. v. Commissioner
United States Tax Court
Held: (1) Computax was formed by petitioner as a wholly owned subsidiary and availed of with a view to the sale by petitioner to CCH of some of its stock prior to the time that a substantial amount of income had been realized from the use of the program for computer preparation of income tax returns developed by petitioner and transferred to Computax; (2) the program for preparation of income tax returns by computer developed by petitioner is intangible property produced by…
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Held: (1) Computax was formed by petitioner as a wholly owned subsidiary and availed of with a view to the sale by petitioner to CCH of some of its stock prior to the time that a substantial amount of income had been realized from the use of the program for computer preparation of income tax returns developed by petitioner and transferred to Computax; (2) the program for preparation of income tax returns by computer developed by petitioner is intangible property produced by petitioner; (3) production of the computer program for preparation of income tax returns had been completed by…
1Opinion of the Court
Computer Sciences Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Computer Sciences Corp. v. Commissioner
Docket No. 3382-70
United States Tax Court
63 T.C. 327; 1974 U.S. Tax Ct. LEXIS 9;
December 16, 1974, Filed
Decision will be entered under Rule 155.
Held: (1) Computax was formed by petitioner as a wholly owned subsidiary and availed of with a view to the sale by petitioner to CCH of some of its stock prior to the time that a substantial amount of income had been realized from the use of the program for computer preparation of income tax returns developed by petitioner…
2Cases cited11 opinions
- Edward Weil and Dorothy Weil v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Temkin v. CommissionerUnited States Tax Court · 1961
- Riley v. CommissionerUnited States Tax Court · 1961
- Jacobson v. CommissionerCourt of Appeals for the Third Circuit · 1960
- John J. Goodrich v. Arnold C. Harmsen and Burke P. Lokey, Burke P. Lokey v. Arnold C. Harmsen and John J. GoodrichCourt of Customs and Patent Appeals · 1971
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