Legal Opinion
Arthur M. And Ruth F. Young v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 13, 1959No. 25348_1PublishedCited by 27 opinions
1Opinion of the Court
LUMBARD, Circuit Judge.
The sole question before us is whether an inventor’s right to terminate an agreement by which he conveyed helicopter patents to an aircraft manufacturer was a “substantial right to a patent” within the meaning of § 117(q) of the Internal Revenue Code of 1939 which permits an inventor to treat as capital gains the royalties received in return for the transfer of all substantial rights to patents. 1
Taxpayers maintain that the power of termination did not preserve any substantial right in the patents because the interests that would have been regained upon the exercise of…
2Cases cited10 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Orla E. Watson and Edith Watson v. United StatesCourt of Appeals for the Tenth Circuit · 1955
- United States v. Eben H. Carruthers and Nancy CarruthersCourt of Appeals for the Ninth Circuit · 1955
- Richard R. Lawrence and Wife, Dorothy Lawrence v. United StatesCourt of Appeals for the Fifth Circuit · 1957
- Rollman v. CommissionerCourt of Appeals for the Fourth Circuit · 1957
5 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Bell Intercontinental Corporation v. The United StatesUnited States Court of Claims · 1967
- Rodgers v. CommissionerUnited States Tax Court · 1969
- Taylor-Winfield Corp. v. Comm'rUnited States Tax Court · 1971
- Rouverol v. Comm'rUnited States Tax Court · 1964
- Hooker Chemicals & Plastics Corp. v. United StatesUnited States Court of Claims · 1979
22 more not listed; retrieve them via the Exa API.