Chamberlin v. Commissioner
United States Tax Court
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
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. HorstSupreme Court of the United States · 1940
- Burnet v. LoganSupreme Court of the United States · 1931
- United States v. DavisSupreme Court of the United States · 1962
- Burnet v. WellsSupreme Court of the United States · 1933
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