Legal Opinion
L. D. Caulk Co. v. United States
District Court, D. Delaware
Decided November 19, 1953No. Civ. A. No. 1393PublishedCited by 2 opinions
1Opinion of the Court
LEAHY, Chief Judge.
This is a suit for refund of penalties and interest assessed and collected on the premise plaintiff’s 1941 and 1942 federal withholding tax returns of royalties *836payable to two non-resident aliens were each filed more than five months late.
Plaintiff, a Delaware corporation, held licenses under patents owned by Robert Doge and Emmanuel de Trey. Both patentees were Swiss. Under two licensing agreements, plaintiff obligated itself to pay royalties semi-annually, fifteen days after the close of each six month period. §§ 143(b) and (c) of the Internal Revenue Code, 26 U.S.C.,1…
2Cases cited12 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- United States v. MurdockSupreme Court of the United States · 1934
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Bus & Transport Securities Corp. v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1935
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3Cited by2 opinions
- Central De Gas De Chihuahua, S.A. v. CommissionerUnited States Tax Court · 1994
- Central De Gas De Chihuahua, S.A. v. CommissionerUnited States Tax Court · 1994