Legal Opinion
Albert A. Mros and Doris Mros v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided March 22, 1974No. 72-1512PublishedCited by 16 opinions
1Per curiam
This appeal from the Tax Court of the United States involves disputed federal income taxes for the year 1966. The legal issue presented by this case is whether a transfer of patent rights by taxpayer 1 subject to a field of use restriction was a transfer of “all substantial rights” to a patent within the meaning of Section 1235 of the Internal Revenue Code of 1954, and thus a capital transaction, even though the taxpayer retained rights in his patent property to license to others outside the fields of use already granted.
This case was submitted to the Tax Court on a stipulation of facts,…
2Cases cited8 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. Eben H. Carruthers and Nancy CarruthersCourt of Appeals for the Ninth Circuit · 1955
- E. I. Du Pont De Nemours and Company v. United StatesCourt of Appeals for the Third Circuit · 1970
- Thomas L. Fawick and Marie Fawick v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1971
- Merck & Co. v. SmithCourt of Appeals for the Third Circuit · 1958
3 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Don and Irene Kueneman, John R. Kueneman, and Edmund W. And Ella M. Harrell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Kueneman v. CommissionerUnited States Tax Court · 1977
- Estate of George T. Klein, Deceased, Shirley Klein, Personal Representative and Shirley Klein v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1974
- Blake v. Comm'rUnited States Tax Court · 1976
- Vision Information Services, L.L.C. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2005
11 more not listed; retrieve them via the Exa API.