Legal Opinion
Broderick, Collector of Internal Revenue v. Neale
Court of Appeals for the Tenth Circuit
Decided January 2, 1953No. 4516PublishedCited by 26 opinions
1Opinion of the Court
PHILLIPS, Chief Judge.
Dory J. Neale 1 brought this action on claims for refund of income taxes for the years 1945, 1946, and 1947. From that part of the judgment awarding a refund of taxes for the year 1945, Broderick, Collector, has appealed.
The question presented is whether a contract relating to patent rights executed August 6, 1945, and effective September 1, 1944, was a license and the income derived thereunder royalties, and, therefore, ordinary income, or whether it constituted an assignment of such patent rights so that such income received thereunder was a part of the purchase price…
2Cases cited15 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Gayler v. WilderSupreme Court of the United States · 1851
- United States v. General Electric Co.Supreme Court of the United States · 1926
- Hotchkiss v. National City Bank of New YorkDistrict Court, S.D. New York · 1911
- Mitchell v. HawleySupreme Court of the United States · 1873
10 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Orla E. Watson and Edith Watson v. United StatesCourt of Appeals for the Tenth Circuit · 1955
- Bell Intercontinental Corporation v. The United StatesUnited States Court of Claims · 1967
- United States v. Eben H. Carruthers and Nancy CarruthersCourt of Appeals for the Ninth Circuit · 1955
- Rollman v. CommissionerCourt of Appeals for the Fourth Circuit · 1957
- Dairy Queen of Oklahoma, Inc. v. CommissionerUnited States Tax Court · 1956
21 more not listed; retrieve them via the Exa API.