Legal Opinion

United States v. Zacks

Supreme Court of the United States

Decided November 21, 1963No. 44PublishedCited by 55 opinions

1Opinion of the CourtJustice Harlan

The question in this case is whether § 117 (q) of the Internal Revenue Code of 1939, a 1956 amendment to the Code which effected retroactive changes in the tax treatment of transfers of patent rights, gives rise to a claim for refund barred by the statute of limitations generally applicable to tax refund claims.

In 1952, Mrs. Zacks received royalties of about $37,000 on patents all substantial rights under which she had transferred by way of an exclusive license to a manufacturing corporation. In accordance with the then prevailing rulings of the Commissioner, the royalties were reported as…

2Cases cited14 opinions

  1. United States v. MenascheSupreme Court of the United States · 1955
  2. United States v. Borden Co.Supreme Court of the United States · 1939
  3. Myers v. Comm'rUnited States Tax Court · 1946
  4. Commissioner of Internal Revenue v. HopkinsonCourt of Appeals for the Second Circuit · 1942
  5. Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951

9 more not listed; retrieve them via the Exa API.

3Cited by55 opinions

  1. Lindh v. MurphySupreme Court of the United States · 1997
  2. United Shoe Workers of America, Afl-Cio v. Catherine Bedell, ChairmanCourt of Appeals for the D.C. Circuit · 1974
  3. Frank James Stevens v. United StatesCourt of Appeals for the Sixth Circuit · 1971
  4. In Re: Cool Fuel,incorporated,debtor. Cool Fuel, Incorporated, a California Corporation v. Board of Equalization of the State of California,appelleeCourt of Appeals for the Ninth Circuit · 2000
  5. Maurice I. Millard v. David W. Harris, Acting Superintendent, St. Elizabeths HospitalCourt of Appeals for the D.C. Circuit · 1968

50 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API