Legal Opinion
Vision Information Services, L.L.C. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided August 22, 2005No. 04-2110PublishedCited by 6 opinions
1Opinion of the Court
OPINION
KAREN NELSON MOORE, Circuit Judge.
This is an appeal from a decision of the United States Tax Court holding that certain sums received by the Petitioner-Appellant, Vision Information Services, L.L.C. (“Vision” or the “taxpayer”), during tax years 1995 and 1996 were license fees and therefore taxable as ordinary income under the Internal Revenue Code. The legal issue presented in this case is whether the agreement between the taxpayer and Twentieth Century Fox Home Entertainment L.L.C. (“FoxVideo”) was a sale of intellectual property and thus a capital transaction, or rather a license…
2Cases cited12 opinions
- Grace Bros. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Schachner v. Blue Cross and Blue Shield of OhioCourt of Appeals for the Sixth Circuit · 1996
- Bell Intercontinental Corporation v. The United StatesUnited States Court of Claims · 1967
- James H. Pickren and Lucie B. Pickren v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- North American Rayon Corporation, Formerly Known as North American Holding Corporation, Narco v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
7 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Indmar Products Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- Freda v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 2011
- Rehabilitation Institute, Inc. v. Michigan United Food & Commercial Workers Health & Welfare FundsCourt of Appeals for the Sixth Circuit · 2006
- Freda v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Seventh Circuit · 2011
- Indmar Products Co v. CIRCourt of Appeals for the Sixth Circuit · 2006
1 more not listed; retrieve them via the Exa API.