American Seating Co. v. Commissioner
United States Board of Tax Appeals
1. Amounts paid for acquiring title to certain inventions represented by applications for patents and expenses incident thereto are capital expenditures and in the instant proceeding must be treated as elements of invested capital. 2. The cost of developing and perfecting the manufacture of a newly designed product is a capital expenditure and where such cost was so treated in the year in which it was incurred and was later charged off to surplus the taxpayer is entitled to…
Read the full summary
1. Amounts paid for acquiring title to certain inventions represented by applications for patents and expenses incident thereto are capital expenditures and in the instant proceeding must be treated as elements of invested capital. 2. The cost of developing and perfecting the manufacture of a newly designed product is a capital expenditure and where such cost was so treated in the year in which it was incurred and was later charged off to surplus the taxpayer is entitled to reinstate the amount in surplus. Appeal of Goodell-Pratt Co.,3 B.T.A. 30.
1Opinion of the Court
APPEAL OF AMERICAN SEATING CO.
American Seating Co. v. Commissioner
Docket No. 4772.
United States Board of Tax Appeals
4 B.T.A. 649; 1926 BTA LEXIS 2240;
July 31, 1926, Decided
1. Amounts paid for acquiring title to certain inventions represented by applications for patents and expenses incident thereto are capital expenditures and in the instant proceeding must be treated as elements of invested capital.
2. The cost of developing and perfecting the manufacture of a newly designed product is a capital expenditure and where such cost was so treated in the year in which it was incurred and was later…
2Cases cited2 opinions
- Goodell-Pratt Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Appeal of American Seating Co.United States Board of Tax Appeals · 1926