Simmonds Precision Prods. v. Comm'r
United States Tax Court
In order to issue stock to the public, petitioner was required to terminate agreements providing for patent royalties and sales commissions payable to corporations controlled by its founder. On May 20, 1960, petitioner terminated the agreements and acquired the patents in exchange for unregistered shares of its stock and options, not immediately exercisable, to purchase additional shares at the public offering price.
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In order to issue stock to the public, petitioner was required to terminate agreements providing for patent royalties and sales commissions payable to corporations controlled by its founder. On May 20, 1960, petitioner terminated the agreements and acquired the patents in exchange for unregistered shares of its stock and options, not immediately exercisable, to purchase additional shares at the public offering price. On June 7, 1960, petitioner sold its stock to the public at a price fixed the day before. The options were exercised in 1968 when the stock had appreciated substantially. Held,…
1Opinion of the Court
Simmonds Precision Products, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Simmonds Precision Prods. v. Comm'r
Docket No. 3130-76
United States Tax Court
75 T.C. 103; 1980 U.S. Tax Ct. LEXIS 39; 211 U.S.P.Q. (BNA) 1210;
October 14, 1980, Filed
In order to issue stock to the public, petitioner was required to terminate agreements providing for patent royalties and sales commissions payable to corporations controlled by its founder. On May 20, 1960, petitioner terminated the agreements and acquired the patents in exchange for unregistered shares of its stock and options, not…
2Cases cited32 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Commissioner v. LoBueSupreme Court of the United States · 1956
- United States v. DavisSupreme Court of the United States · 1962
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- Commissioner v. SmithSupreme Court of the United States · 1945
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