Ill. Tool Works v. Comm'r
United States Tax Court
P acquired the assets of D and assumed certain liabilities, including the contingent liability for a patent infringement claim. P was subsequently held liable for damages, interest, and court costs. HELD: P's payment in satisfaction of the patent infringement liability is a cost of acquiring the assets of D and must be capitalized in the year incurred.
1Opinion of the Court
ILLINOIS TOOL WORKS, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ill. Tool Works v. Comm'r
No. 16022-99
United States Tax Court
117 T.C. 39; 2001 U.S. Tax Ct. LEXIS 35; 117 T.C. No. 4;
July 31, 2001, Filed
Decision will be entered under Rule 155.
P acquired the assets of D and assumed certain liabilities,
including the contingent liability for a patent infringement
claim. P was subsequently held liable for damages, interest, and
court costs.
HELD: P's payment in satisfaction of the patent
infringement liability is a cost of acquiring the assets of D
and must be…
2Cases cited17 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. TellierSupreme Court of the United States · 1966
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
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