Perfumers Mfg. Corp. v. Commissioner
United States Tax Court
Petitioner's transferor, Pinaud, Inc., transferred its business to Ed. Pinaud under a contract in 1947, providing for the payment of annual royalty to Pinaud, Inc. This contract also provided the cash payment made thereunder in 1947, and the payments made thereafter in discharge of Pinaud, Inc.'s, merchandising obligations were to be a charge against the future royalty payments.
Read the full summary
Petitioner's transferor, Pinaud, Inc., transferred its business to Ed. Pinaud under a contract in 1947, providing for the payment of annual royalty to Pinaud, Inc. This contract also provided the cash payment made thereunder in 1947, and the payments made thereafter in discharge of Pinaud, Inc.'s, merchandising obligations were to be a charge against the future royalty payments. The Commissioner allowed the cash payment in the sum of about $ 52,000 as prepayment of royalty income. No royalty payments were made in the years in question. Held, the payments made by Ed. Pinaud in years prior to…
1Opinion of the Court
Perfumers Manufacturing Corporation, Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent
Perfumers Mfg. Corp. v. Commissioner
Docket No. 66863
United States Tax Court
33 T.C. 532; 1959 U.S. Tax Ct. LEXIS 11;
December 17, 1959, Filed
Decision will be entered under Rule 50.
Petitioner's transferor, Pinaud, Inc., transferred its business to Ed. Pinaud under a contract in 1947, providing for the payment of annual royalty to Pinaud, Inc. This contract also provided the cash payment made thereunder in 1947, and the payments made thereafter in discharge of Pinaud, Inc.'s, merchandising…
2Cases cited3 opinions
- Crossett Timber & Development Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- C. H. Mead Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Perfumers Mfg. Corp. v. CommissionerUnited States Tax Court · 1959