Texas Instruments v. Commissioner
United States Tax Court
P collected and processed seismic data and information, which was recorded on output tapes. P used those original tapes to produce copies that it sold to its nonexclusive customers, who used the licensed data and information on those copies for the purpose of exploring for resources on the Outer Continental Shelf.
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P collected and processed seismic data and information, which was recorded on output tapes. P used those original tapes to produce copies that it sold to its nonexclusive customers, who used the licensed data and information on those copies for the purpose of exploring for resources on the Outer Continental Shelf. Held, those original tapes were not property of a U.S. person used within the meaning of sec. 48(a)(2)(B)(vi), I.R.C., and P is not entitled to claim an investment tax credit thereon.
1Opinion of the Court
Texas Instruments Incorporated and Its Consolidated Subsidiaries, Petitioner v. Commissioner of Internal Reveune, Respondent
Texas Instruments v. Commissioner
Docket No. 32707-88
United States Tax Court
98 T.C. 628; 1992 U.S. Tax Ct. LEXIS 47; 98 T.C. No. 43;
May 27, 1992, Filed
Decision will be entered under Rule 155.
P collected and processed seismic data and information, which was recorded on output tapes. P used those original tapes to produce copies that it sold to its nonexclusive customers, who used the licensed data and information on those copies for the purpose of exploring for resources…
2Cases cited15 opinions
- United States v. PriceSupreme Court of the United States · 1960
- E. I. Du Pont De Nemours and Company v. United StatesCourt of Appeals for the Third Circuit · 1970
- Walt Disney Productions v. United States of America, Walt Disney Productions v. United StatesCourt of Appeals for the Ninth Circuit · 1973
- Texas Instruments Incorporated, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Olin Bryant and Vanell Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
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