Hopkins v. Commissioner
United States Tax Court
1. Petitioner received certain annual payments from a drug manufacturer by reason of a licensing arrangement between the manufacturer and petitioner's great-grandfather which provided for use by the manufacturer of a medical formula developed by petitioner's ancestor.
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1. Petitioner received certain annual payments from a drug manufacturer by reason of a licensing arrangement between the manufacturer and petitioner's great-grandfather which provided for use by the manufacturer of a medical formula developed by petitioner's ancestor. These payments held royalty income taxable in full to petitioner. 2. Anticipatory assignment by petitioner of a portion of above royalty payments in order to discharge an alimony obligation of petitioner held ineffective to relieve petitioner of taxability on the sums so assigned. 3. Held, petitioner was not entitled to deduct…
1Opinion of the Court
John Randolph Hopkins, Petitioner, v. Commissioner of Internal Revenue, Respondent
Hopkins v. Commissioner
Docket No. 9931
United States Tax Court
15 T.C. 160; 1950 U.S. Tax Ct. LEXIS 105;
August 29, 1950, Promulgated
Decision will be entered under Rule 50.
1. Petitioner received certain annual payments from a drug manufacturer by reason of a licensing arrangement between the manufacturer and petitioner's great-grandfather which provided for use by the manufacturer of a medical formula developed by petitioner's ancestor. These payments held royalty income taxable in full to petitioner.
2.…
2Cases cited30 opinions
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- Helvering v. HorstSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Douglas v. WillcutsSupreme Court of the United States · 1935
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