Brunson Instrument Co. v. Commissioner
United States Tax Court
Petitioner acquired patents from a stockholder, who obtained the patents, under a tax-free exchange of its stock for the patents. Its cost basis for the patents was the same as the transferor's cost. For lack of substantiation of the alleged cost basis, respondent determined that petitioner's basis was zero. Upon the entire record, petitioner's cost basis of each patent is determined and deductions are allowed in the taxable years for depreciation.
1Opinion of the Court
Brunson Instrument Company v. Commissioner.
Brunson Instrument Co. v. Commissioner
Docket No. 62663.
United States Tax Court
T.C. Memo 1957-154; 1957 Tax Ct. Memo LEXIS 110; 16 T.C.M. (CCH) 632; T.C.M. (RIA) 57154;
July 31, 1957
Petitioner acquired patents from a stockholder, who obtained the patents, under a tax-free exchange of its stock for the patents. Its cost basis for the patents was the same as the transferor's cost. For lack of substantiation of the alleged cost basis, respondent determined that petitioner's basis was zero. Upon the entire record, petitioner's cost basis of each patent is…
2Cases cited1 opinion
- Polish Army Veterans Post 147 v. CommissionerUnited States Tax Court · 1955