Hitchcock v. Commissioner
United States Board of Tax Appeals
PATENTS; BASIS OF DEDUCTION FOR EXHAUSTION. - The owner of certain patents in the year 1912 granted the exclusive right of user during the life of the latest patent. The basis for the statutory deduction on account of exhaustion held to be the March 1, 1913, value of the contract, and, upon the evidence, the value of that contract found to be the amount of $100,000.
1Opinion of the Court
*275OPINION.
TRUssell:
The testimony presented in this proceeding is in the form of depositions taken at Pittsburgh, Pa. At the taking of such depositions the Commissioner objected to testimony given by officers of the Glass Company concerning the value of the patents to the Glass Company and their opinions as to the value of the leasing contract to the petitioner. Like objection was made by the Commissioner to the testimony concerning the amounts of royalty payments received by the petitioner for years subsequent to 1913. All of this evidence, although not to be considered as determinative of the…
2Cited by4 opinions
- Gilmartin v. CommissionerUnited States Tax Court · 1973
- Hitchcock v. CommissionerUnited States Board of Tax Appeals · 1926
- Schahet v. CommissionerUnited States Tax Court · 1959
- Yeager v. CommissionerUnited States Tax Court · 1959