Coplan v. Comm'r
United States Tax Court
The owner of a patent assigned all of her interest therein to a corporation owned 50 per cent by her and 50 per cent by her husband in exchange for payments based on net sales. Held: On the record in this case the assignment was a "sale or exchange." Edward C. Myers, 6 T. C. 258, followed.
1Opinion of the Court
OPINION.
Raum, Judge:
The Commissioner determined deficiencies in petitioners’ income tax and an addition to tax as follows:'
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The principal question for decision is whether certain payments received by petitioner Raye Coplan pursuant to an agreement transferring patent rights are ordinary income or capital gain. Leonard Coplan is Raye’s husband and is also a petitioner because they filed j oint returns for the years in question. The facts have been stipulated.
Raye is the inventor of a device for the simplified operation of marionettes. On March 10,1947, she filed an application for…
2Cases cited9 opinions
- Myers v. Comm'rUnited States Tax Court · 1946
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
- Orla E. Watson and Edith Watson v. United StatesCourt of Appeals for the Tenth Circuit · 1955
- United States v. Eben H. Carruthers and Nancy CarruthersCourt of Appeals for the Ninth Circuit · 1955
- Marco v. CommissionerUnited States Tax Court · 1955
4 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Green v. Comm'rUnited States Tax Court · 1984
- United States Mineral Products Co. v. CommissionerUnited States Tax Court · 1969
- Best Lock Corp. v. CommissionerUnited States Tax Court · 1959
- Chilton v. CommissionerUnited States Tax Court · 1963
- Hamrick v. CommissionerUnited States Tax Court · 1964
30 more not listed; retrieve them via the Exa API.