Legal Opinion

International Banding Machine Co. v. Commissioner

United States Board of Tax Appeals

Decided June 30, 1928No. Docket No. 13744PublishedCited by 2 opinions

The cash value of an application for a patent paid into the petitioner corporation in 1907 in exchange for shares of stock and cash determined.

1Opinion of the Court

*1065OPINION.

Smith:

The only assignment of error stated in the petition which was not waived at the hearing is the disallowance by the respondent of patents in an amount of $219,700 as part of petitioner’s invested capital for the year 1921. The amount claimed in the return filed for 1921 is not in evidence. The deficiency notice sent to the petitioner by the respondent states:

Since the cash value of patents acquired with stock has not been established, depreciation has been disallowed on all patents acquired for stock. Depreciation on patents acquired lor cash is computed as follows:

Cost Rate…

2Cited by2 opinions

  1. Behr v. CommissionerUnited States Board of Tax Appeals · 1934
  2. International Banding Machine Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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