Hazeltine Corp. v. Commissioner
United States Board of Tax Appeals
1. (a) EXHAUSTION AND OBSOLESCENCE OF PATENTS, ETC. - BASIS. - On February 2, 1924, corporation X, sole stockholder A, individual B, and bankers C agreed to organize a new corporation (petitioner). X agreed to transfer substantially all its assets, business and good will, B certain inventions, and C $50,000 in cash to the new corporation for 155,250, 14,750, and 5,000 shares of the latter's no par value stock, respectively, and in the same agreement X agreed to sell C…
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1. (a) EXHAUSTION AND OBSOLESCENCE OF PATENTS, ETC. - BASIS. - On February 2, 1924, corporation X, sole stockholder A, individual B, and bankers C agreed to organize a new corporation (petitioner). X agreed to transfer substantially all its assets, business and good will, B certain inventions, and C $50,000 in cash to the new corporation for 155,250, 14,750, and 5,000 shares of the latter's no par value stock, respectively, and in the same agreement X agreed to sell C 135,000 of such new shares for $650,000 cash. Contract was executed on February 19, 1924. Held, that an ownership, interest,…
1Opinion of the Court
HAZELTINE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hazeltine Corp. v. Commissioner
Docket Nos. 42277, 47011, 51931, 60313.
United States Board of Tax Appeals
32 B.T.A. 4; 1935 BTA LEXIS 1008;
February 7, 1935, Promulgated
1. (a) EXHAUSTION AND OBSOLESCENCE OF PATENTS, ETC. - BASIS. - On February 2, 1924, corporation X, sole stockholder A, individual B, and bankers C agreed to organize a new corporation (petitioner). X agreed to transfer substantially all its assets, business and good will, B certain inventions, and C $50,000 in cash to the new corporation for…
2Cases cited5 opinions
- Hershey Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Ambassador Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Norwich Pharmacal Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Seymour Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Hazeltine Corp. v. CommissionerUnited States Board of Tax Appeals · 1935