Snow v. Commissioner
United States Tax Court
Snow, an executive in a large corporation, invested money and gave advisory services in three limited partnerships formed in 1965 and 1966, each to carry on research and experimentation upon a particular invention with a view to profit. In 1966 two of the inventions were held for licensing to manufacturers but none were so licensed in that year.
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Snow, an executive in a large corporation, invested money and gave advisory services in three limited partnerships formed in 1965 and 1966, each to carry on research and experimentation upon a particular invention with a view to profit. In 1966 two of the inventions were held for licensing to manufacturers but none were so licensed in that year. The third invention, a trash burner, was not sufficiently developed to be ready for sale or licensing in 1966. The partnership developing this invention had no income in 1966 but reported a net loss by reason of a deduction claimed under sec. 174(a),…
1Opinion of the Court
Edwin A. Snow and Helen B. Snow, Petitioners v. Commissioner of Internal Revenue, Respondent
Snow v. Commissioner
Docket No. 7125-70
United States Tax Court
58 T.C. 585; 1972 U.S. Tax Ct. LEXIS 93;
June 30, 1972, Filed
Decision will be entered for the respondent.
Snow, an executive in a large corporation, invested money and gave advisory services in three limited partnerships formed in 1965 and 1966, each to carry on research and experimentation upon a particular invention with a view to profit. In 1966 two of the inventions were held for licensing to manufacturers but none were so licensed in that…
2Cases cited20 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Frank v. CommissionerUnited States Tax Court · 1953
- Polachek v. CommissionerUnited States Tax Court · 1954
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