Urquhart v. Comm'r
United States Tax Court
Litigation expenses incurred by the petitioners in a suit attacking the validity of patents issued to them held to be capital in nature and not deductible as ordinary and necessary business expenses or as losses incurred in trade or business.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The sole issue to be decided is the propriety of deductions taken by the petitioners as expenses in the suit brought by the Pyrene Manufacturing Company. The issue with respect to the traveling expense deduction taken by Kadcliffe M. Urquhart has apparently been abandoned as no evidence with respect to this issue has been introduced and no argument made thereon.
Two of the three petitioners were issued mechanical foam patents relating to fire extinguishment equipment. The petitioners carried on the joint venture to develop and license these inventions. Title to the…
2Cases cited10 opinions
- Safety Tube Corp. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1948
- Safety Tube Corp. v. CommissionerUnited States Tax Court · 1947
- Coughlin v. CommissionerUnited States Tax Court · 1944
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Farmer v. CommissionerCourt of Appeals for the Tenth Circuit · 1942
5 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Alleghany Corp. v. CommissionerUnited States Tax Court · 1957
- Urquhart v. Commissioner of Internal Revenue, (Two Cases). Urquhart v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
- Arata v. CommissionerUnited States Tax Court · 1958
- Alleghany Corp. v. CommissionerUnited States Tax Court · 1957
- Arata v. CommissionerUnited States Tax Court · 1958
1 more not listed; retrieve them via the Exa API.