Legal Opinion

Chamberlin v. Commissioner

United States Tax Court

Decided August 20, 1959No. Docket Nos. 63557, 63558, 63559Published

1. Laundri-Matic Corporation assigned to Chamberlin, in exchange for 26 shares of Laundri-Matic stock, the right to receive 26 per cent of all royalties payable to Laundri-Matic by Hydraulic Brake Company under an exclusive license agreement to make, use, and sell domestic laundry machines granted by Laundri-Matic to Hydraulic.

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1. Laundri-Matic Corporation assigned to Chamberlin, in exchange for 26 shares of Laundri-Matic stock, the right to receive 26 per cent of all royalties payable to Laundri-Matic by Hydraulic Brake Company under an exclusive license agreement to make, use, and sell domestic laundry machines granted by Laundri-Matic to Hydraulic. Held, the royalties received under this assignment in 1947, 1948, and 1949 are taxable as ordinary income rather than capital gain. 2. Held, payments received by Marian Chamberlin from Borg-Warner Corporation under an exclusive license agreement were not consideration…

1Opinion of the Court

John W. Chamberlin and Marian McMichael Chamberlin, husband and wife, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Chamberlin v. Commissioner

Docket Nos. 63557, 63558, 63559

United States Tax Court

32 T.C. 1098; 1959 U.S. Tax Ct. LEXIS 102;

August 20, 1959, Filed

Decisions will be entered under Rule 50.

1. Laundri-Matic Corporation assigned to Chamberlin, in exchange for 26 shares of Laundri-Matic stock, the right to receive 26 per cent of all royalties payable to Laundri-Matic by Hydraulic Brake Company under an exclusive license agreement to make, use, and sell domestic…

Also in this document: Concurring in part, dissenting in part.

2Cases cited24 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Helvering v. HorstSupreme Court of the United States · 1940
  3. Burnet v. LoganSupreme Court of the United States · 1931
  4. United States v. DavisSupreme Court of the United States · 1962
  5. Burnet v. WellsSupreme Court of the United States · 1933

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