Legal Opinion

Snow v. Commissioner

United States Tax Court

Decided June 30, 1972No. Docket No. 7125-70Published

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.

Read the full summary

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

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Higgins v. CommissionerSupreme Court of the United States · 1941
  3. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
  4. Frank v. CommissionerUnited States Tax Court · 1953
  5. Polachek v. CommissionerUnited States Tax Court · 1954

15 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API