Cold Metal Process Co. v. Commissioner
United States Tax Court
1. Monies due under settlement agreements made in 1945 compromising claims growing out of alleged patent infringement, none of which were paid to petitioner in that year but which were then largely deposited in court in litigation affecting their disposition, held, not accruable as income for 1945. 2. Attorneys' fees for services rendered in 1945 and other years but not determined in amount and billed until 1946, held, not deductible by an accrual taxpayer for 1945.
1Opinion of the Court
The Cold Metal Process Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Cold Metal Process Co. v. Commissioner
Docket No. 22486
United States Tax Court
17 T.C. 916; 1951 U.S. Tax Ct. LEXIS 22;
December 4, 1951, Promulgated
Decision will be entered under Rule 50.
1. Monies due under settlement agreements made in 1945 compromising claims growing out of alleged patent infringement, none of which were paid to petitioner in that year but which were then largely deposited in court in litigation affecting their disposition, held, not accruable as income for 1945.
2. Attorneys' fees for…
2Cases cited22 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Brown v. HelveringSupreme Court of the United States · 1934
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Safety Tube Corp. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
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