Chu v. Comm'r
United States Tax Court
Held, assignment of patent application was not productive of ordinary income within the provision of sec. 1239, I.R.C. 1954; such application was not property of a character subject to depreciation within the meaning of sec. 1239(b), whether considered in the light of Estate of William F. Stahl, 52 T.C. 591, or in the light of the reversal of that decision in part by the Court of Appeals, 442 F. 2d 324 (C.A. 7).
1Opinion of the Court
Lan Jen Chu and Grace Y. P. Chu, Petitioners v. Commissioner of Internal Revenue, Respondent
Chu v. Comm'r
Docket No. 4802-69
United States Tax Court
58 T.C. 598; 1972 U.S. Tax Ct. LEXIS 92; 175 U.S.P.Q. (BNA) 367;
July 10, 1972, Filed
Decision will be entered under Rule 50.
Held, assignment of patent application was not productive of ordinary income within the provision of sec. 1239, I.R.C. 1954; such application was not property of a character subject to depreciation within the meaning of sec. 1239(b), whether considered in the light of Estate of William F. Stahl, 52 T.C. 591, or in the light of…
2Cases cited9 opinions
- Hershey Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- United States Mineral Products Co. v. CommissionerUnited States Tax Court · 1969
- Hershey Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1930
- Estate of Stahl v. Comm'rUnited States Tax Court · 1969
- Speicher v. Comm'rUnited States Tax Court · 1957
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