Dwight & Lloyd Sintering Co. v. Commissioner
United States Board of Tax Appeals
License agreements authorizing the licensees to make and use certain patented machines for refining ores, acquired for stock by a corporation, are intangible property for invested capital purposes and as such are subject to the limitation on intangibles contained in the Revenue Act of 1917. The value of assets acquired by a corporation for stock should be determined on the basis of facts known at the time of the acquisition, or facts reasonably anticipated.
Read the full summary
License agreements authorizing the licensees to make and use certain patented machines for refining ores, acquired for stock by a corporation, are intangible property for invested capital purposes and as such are subject to the limitation on intangibles contained in the Revenue Act of 1917. The value of assets acquired by a corporation for stock should be determined on the basis of facts known at the time of the acquisition, or facts reasonably anticipated. Subsequent events or earnings, when reasonably anticipated, may be shown for the purpose of demonstration or corroboration of actually…
1Opinion of the Court
Appeal of DWIGHT & LLOYD SINTERING CO., INC.
Dwight & Lloyd Sintering Co. v. Commissioner
Docket No. 120.
United States Board of Tax Appeals
1 B.T.A. 179; 1924 BTA LEXIS 209;
December 18, 1924, decided Submitted October 24, 1924.
License agreements authorizing the licensees to make and use certain patented machines for refining ores, acquired for stock by a corporation, are intangible property for invested capital purposes and as such are subject to the limitation on intangibles contained in the Revenue Act of 1917.
The value of assets acquired by a corporation for stock should be determined on the…
2Cases cited1 opinion
- Dwight & Lloyd Sintering Co. v. CommissionerUnited States Board of Tax Appeals · 1924