Estate of Paxton v. Commissioner
United States Tax Court
Floyd Paxton, the decedent of the petitioner estate invented and patented plastic closures. He licensed the patents to corporation Y which, in turn, granted its subsidiary, petitioner corporation I, non-exclusive licenses to exploit the patents. Paxton later invented and patented plastic closures with labels attached and assigned these latter patents to IDT, a family trust.
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Floyd Paxton, the decedent of the petitioner estate invented and patented plastic closures. He licensed the patents to corporation Y which, in turn, granted its subsidiary, petitioner corporation I, non-exclusive licenses to exploit the patents. Paxton later invented and patented plastic closures with labels attached and assigned these latter patents to IDT, a family trust. IDT sold the patents to petitioner corporation Y, which then granted petitioner corporation I an exclusive license to exploit the patents. The corporation granted an exclusive license to another petitioner corporation.…
1Opinion of the Court
ESTATE OF FLOYD G. PAXTON, JERRE PAXTON, EXECUTOR, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Paxton v. Commissioner
Docket Nos. 4639-76, 4644-76, 4645-76, 4647-76, 4648-76.
United States Tax Court
T.C. Memo 1982-464; 1982 Tax Ct. Memo LEXIS 285; 44 T.C.M. (CCH) 771; T.C.M. (RIA) 82464;
August 9, 1982.
Floyd Paxton, the decedent of the petitioner estate invented and patented plastic closures. He licensed the patents to corporation Y which, in turn, granted its subsidiary, petitioner corporation I, non-exclusive licenses to exploit the patents. Paxton later…
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