Ransburg Corporation and Subsidiaries v. Commissioner of Internal Revenue

H ARLINGTON WOOD, Jr., Circuit Judge.

In this appeal from the United States Tax Court, 1 the issue is whether the Tax Court correctly held that interest was properly imputed under Section 483 of the Internal Revenue Code 2 to deferred payments received during taxable years ending on November 30 for the years 1966 through 1972 by the taxpayer corporation in accordance with a contract for the sale of its patents, patent and utility model applications and trademarks to a Japanese corporation. The Tax Court found income tax deficiencies resulting from the imputed interest to exist for the six…