Legal Opinion

Christensen v. Commissioner

United States Board of Tax Appeals

Decided September 24, 1935No. Docket No. 72424Published

Taxpayer owned a patent expiring in 1916, license to use which had been granted to another party by contract providing for royalties. Beginning December 1, 1906, the licensee failed to make payment of royalties, but continued to use the patent. In 1909 taxpayer sued for infringement. In 1930 final judgment was entered for taxpayer, awarding him $296,511.44 on account of damages and interest.

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Taxpayer owned a patent expiring in 1916, license to use which had been granted to another party by contract providing for royalties. Beginning December 1, 1906, the licensee failed to make payment of royalties, but continued to use the patent. In 1909 taxpayer sued for infringement. In 1930 final judgment was entered for taxpayer, awarding him $296,511.44 on account of damages and interest. This sum represented the amount of royalties provided by the contract plus interest to date of expiration of the patent, of which $103,589.34 represented the royalties and interest accrued to March 1,…

1Opinion of the Court

NIELS A. CHRISTENSEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Christensen v. Commissioner

Docket No. 72424.

United States Board of Tax Appeals

33 B.T.A. 79; 1935 BTA LEXIS 812;

September 24, 1935, Promulgated

Taxpayer owned a patent expiring in 1916, license to use which had been granted to another party by contract providing for royalties. Beginning December 1, 1906, the licensee failed to make payment of royalties, but continued to use the patent. In 1909 taxpayer sued for infringement. In 1930 final judgment was entered for taxpayer, awarding him $296,511.44 on account of…

2Cases cited1 opinion

  1. Christensen v. CommissionerUnited States Board of Tax Appeals · 1935

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