Legal Opinion
United States Mineral Products Co. v. Commissioner
United States Tax Court
Decided May 5, 1969No. Docket No. 4733-66PublishedCited by 29 opinions
1Opinion of the Court
OPINION
Eespondent’s position that the payments in issue are taxable as ordinary income is based upon four principal arguments: (1) The Canadian agreement was not a bona fide agreement of sale but rather a paper transaction set up between a parent corporation and its wholly owned subsidiary to alter the tax consequences of a preexisting licensing arrangement; (2) petitioner did not own the patents listed in the Canadian agreement but had only the right to grant CAFCAN a nonexclusive license to manufacture and to license others to use the patents in Canada; (3) the CAFCO formulas and “know-how”…
2Cases cited32 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Watson v. CommissionerSupreme Court of the United States · 1953
- Williams v. McGowanCourt of Appeals for the Second Circuit · 1945
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
27 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- Montgomery Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1980
- Taylor-Winfield Corp. v. Comm'rUnited States Tax Court · 1971
- Estate of Stahl v. Comm'rUnited States Tax Court · 1969
- Hooker Chemicals & Plastics Corp. v. United StatesUnited States Court of Claims · 1979
24 more not listed; retrieve them via the Exa API.