Legal Opinion
Potter v. Commissioner
United States Tax Court
Decided October 31, 1956No. Docket No. 52506PublishedCited by 2 opinions
1Opinion of the Court
OPINION.
AnuNDEUi, Judge:
The respondent contends that his determination under the first and principal issue must be sustained on any one of several grounds, namely: (1) That petitioner has failed to prove that the trust instrument in question was executed prior to December 31, 1946; (2) that petitioner has failed to prove that he made a valid assignment and delivery of the patent application to the trusts; (3) that assuming a valid assignment and delivery, petitioner has still failed to prove that he made a valid inter vivos gift of the patent application to the trusts in that he continued to…
2Cases cited17 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Fuller v. CommissionerUnited States Tax Court · 1953
- Limericks, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
- Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
- Brown v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1950
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3Cited by2 opinions
- Talge v. United StatesDistrict Court, W.D. Missouri · 1964
- Potter v. Comm'rUnited States Tax Court · 1956