Legal Opinion

Coe Laboratories, Inc. v. Commissioner

United States Tax Court

Decided June 24, 1960No. Docket No. 50268Published

1. For many years, among other activities, petitioner has been engaged in the development and selling of dental impression materials. Beginning in February 1941 and continuing through the taxable years petitioner conducted research on an alginate impression material, the sales of which gave rise to income during the taxable years 1943 to 1946, inclusive.

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1. For many years, among other activities, petitioner has been engaged in the development and selling of dental impression materials. Beginning in February 1941 and continuing through the taxable years petitioner conducted research on an alginate impression material, the sales of which gave rise to income during the taxable years 1943 to 1946, inclusive. Held, petitioner has failed to prove that any portion of its income for the years 1943 to 1946, of the class described in section 721(a)(2)(C) of the Internal Revenue Code of 1939, as amended, was "net abnormal income" resulting from research…

1Opinion of the Court

Coe Laboratories, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Coe Laboratories, Inc. v. Commissioner

Docket No. 50268

United States Tax Court

34 T.C. 549; 1960 U.S. Tax Ct. LEXIS 121;

June 24, 1960, Filed

Decision will be entered under Rule 50.

1. For many years, among other activities, petitioner has been engaged in the development and selling of dental impression materials. Beginning in February 1941 and continuing through the taxable years petitioner conducted research on an alginate impression material, the sales of which gave rise to income during the taxable years 1943 to…

2Cases cited13 opinions

  1. Place v. CommissionerUnited States Tax Court · 1951
  2. Avey Drilling Machine Co. v. CommissionerUnited States Tax Court · 1951
  3. W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
  4. Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
  5. Producers Crop Improv. Asso. v. CommissionerUnited States Tax Court · 1946

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