Legal Opinion

Elliott v. Commissioner

United States Board of Tax Appeals

Decided September 11, 1931No. Docket Nos. 32632, 42454Published

Held, payments made to the taxpayer of an agreed percentage of rentals, collected by his licensee, for use of an invention of which the taxpayer was part owner, are taxable income to him for the year received.

1Opinion of the Court

FRANK W. ELLIOTT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Elliott v. Commissioner

Docket Nos. 32632, 42454.

United States Board of Tax Appeals

24 B.T.A. 5; 1931 BTA LEXIS 1712;

September 11, 1931, Promulgated

Held, payments made to the taxpayer of an agreed percentage of rentals, collected by his licensee, for use of an invention of which the taxpayer was part owner, are taxable income to him for the year received.

G. E. Brammer, Esq., and L. Call Dickinson, Esq., for the petitioner.

B. M. Coon, Esq., for the respondent.

LANSDON

OPINION.

LANSDON: These consolidated appeals have been…

2Cases cited1 opinion

  1. Elliott v. CommissionerUnited States Board of Tax Appeals · 1931

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