Legal Opinion

Hopkinson v. Commissioner

United States Board of Tax Appeals

Decided August 20, 1940No. Docket No. 97014Published

1. An agreement whereby a patentee "does grant, bargain, sell, convey, transfer, assign, set over and deliver" certain patent applications to a corporation in consideration of the latter's promise to pay over to the patentee amounts realized from the manufacture and sale of the patented products and from licensing agreements in respect of the patents, followed by recordation both of the general assignment and the individual assignments of each patent and patent application,…

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1. An agreement whereby a patentee "does grant, bargain, sell, convey, transfer, assign, set over and deliver" certain patent applications to a corporation in consideration of the latter's promise to pay over to the patentee amounts realized from the manufacture and sale of the patented products and from licensing agreements in respect of the patents, followed by recordation both of the general assignment and the individual assignments of each patent and patent application, held, to be contract for the sale of a capital asset, and moneys received thereunder by the seller and/or his assignee…

1Opinion of the Court

BESSIE B. HOPKINSON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Hopkinson v. Commissioner

Docket No. 97014.

United States Board of Tax Appeals

42 B.T.A. 580; 1940 BTA LEXIS 980;

August 20, 1940, Promulgated

1. An agreement whereby a patentee "does grant, bargain, sell, convey, transfer, assign, set over and deliver" certain patent applications to a corporation in consideration of the latter's promise to pay over to the patentee amounts realized from the manufacture and sale of the patented products and from licensing agreements in respect of the patents, followed by recordation…

2Cases cited2 opinions

  1. Hopkinson v. CommissionerUnited States Board of Tax Appeals · 1940
  2. Reese v. CommissionerUnited States Board of Tax Appeals · 1933

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