Legal Opinion

Ill. Tool Works v. Comm'r

United States Tax Court

Decided July 31, 2001No. 16022-99Published

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

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  3. Commissioner v. TellierSupreme Court of the United States · 1966
  4. Woodward v. CommissionerSupreme Court of the United States · 1970
  5. Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971

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