William M. Bailey Co. v. Commissioner
United States Tax Court
1. Royalties on patented blast furnace specialties paid under licensing agreements by petitioner corporation to its president held deductible in year of payment. 2. Deposits of insurance premiums by petitioner with trustees under a stock bonus plan creating forfeitable beneficial interests in the officer-beneficiaries, held not deductible.
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1. Royalties on patented blast furnace specialties paid under licensing agreements by petitioner corporation to its president held deductible in year of payment. 2. Deposits of insurance premiums by petitioner with trustees under a stock bonus plan creating forfeitable beneficial interests in the officer-beneficiaries, held not deductible. Section 23 (p) (1) (D), Internal Revenue Code. 3. Amount for which liability was recognized and evidenced by accrual in tax year, held properly accruable. 4. Petitioner, having received net abnormal income in tax years partially attributable to research or…
1Opinion of the Court
William M. Bailey Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
William M. Bailey Co. v. Commissioner
Docket No. 22615
United States Tax Court
15 T.C. 468; 1950 U.S. Tax Ct. LEXIS 69;
October 10, 1950, Promulgated
Decision will be entered under Rule 50.
1. Royalties on patented blast furnace specialties paid under licensing agreements by petitioner corporation to its president held deductible in year of payment.
2. Deposits of insurance premiums by petitioner with trustees under a stock bonus plan creating forfeitable beneficial interests in the officer-beneficiaries, held not…
2Cases cited9 opinions
- W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
- Lord v. CommissionerUnited States Tax Court · 1942
- Times Publishing Co. v. CommissionerUnited States Tax Court · 1949
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