United States v. Zacks
Supreme Court of the United States
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
- United States v. MenascheSupreme Court of the United States · 1955
- United States v. Borden Co.Supreme Court of the United States · 1939
- Myers v. Comm'rUnited States Tax Court · 1946
- Commissioner of Internal Revenue v. HopkinsonCourt of Appeals for the Second Circuit · 1942
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
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- Maurice I. Millard v. David W. Harris, Acting Superintendent, St. Elizabeths HospitalCourt of Appeals for the D.C. Circuit · 1968
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