Best Universal Lock Co. v. Commissioner
United States Tax Court
1. Corporate petitioner engaged in the manufacture and sale of locks expended large sums for research and development of locks and other products not related to locks.
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1. Corporate petitioner engaged in the manufacture and sale of locks expended large sums for research and development of locks and other products not related to locks. Held, all such research and development expenditures were paid in "connection with" petitioner's business and deductible under section 174(a)(1), I.R.C. 1954. 2. Held, further, that when corporate petitioner's leasehold interest in its factory was taken in condemnation by the State of Indiana, it was entitled to take its moving expenses as a deduction without showing that moving expenses were not an item of damages allowed in…
1Opinion of the Court
Mulroney, Judge:
Respondent determined the following deficiencies in the petitioners’ income taxes:
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The issues in these consolidated cases are (1) whether Best Lock Corp. is entitled to deductions under section 174 of the Internal Revenue Code of 19542 for certain research and development expenses in 1959,1960, and 1961; (2) whether the research and development expenses incurred by Best Lock Corp. in 1959, 1960, and 1961 are, in fact, constructive dividends to Frank E. Best in those years; (3) in the event that the research and development expenditures of Best Lock Corp. are…
2Cases cited9 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Mayrath v. CommissionerUnited States Tax Court · 1964
- Martin v. CommissionerUnited States Tax Court · 1965
- Best Lock Corp. v. CommissionerUnited States Tax Court · 1959
- Electric Tachometer Corp. v. CommissionerUnited States Tax Court · 1961
4 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Green v. Comm'rUnited States Tax Court · 1984
- O'Donnell v. CommissionerUnited States Tax Court · 1974
- Montgomery v. CommissionerUnited States Tax Court · 1975
- Martin Mayrath and Rose Mayrath v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Jack P, Stanton and Virginia G. Stanton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
16 more not listed; retrieve them via the Exa API.