Legal Opinion

General Tire & Rubber Co. v. Commissioner

United States Tax Court

Decided February 27, 1958No. Docket No. 51537Published

Petitioner, a manufacturer of coated fabrics, engaged in a program of research resulting in the development of a resin coating known as Tolex.

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Petitioner, a manufacturer of coated fabrics, engaged in a program of research resulting in the development of a resin coating known as Tolex. Held, a portion of the income resulting from the sale of Tolex constitutes net abnormal income resulting from research and development within the meaning of section 721 (a) (2) (C), I. R. C. 1939, and is allocable to the years during which the research and development program was in operation, pursuant to section 721 (b), I. R. C. 1939.

1Opinion of the Court

General Tire & Rubber Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

General Tire & Rubber Co. v. Commissioner

Docket No. 51537

United States Tax Court

29 T.C. 975; 1958 U.S. Tax Ct. LEXIS 248;

February 27, 1958, Filed

Decision will be entered under Rule 50.

Petitioner, a manufacturer of coated fabrics, engaged in a program of research resulting in the development of a resin coating known as Tolex. Held, a portion of the income resulting from the sale of Tolex constitutes net abnormal income resulting from research and development within the meaning of section 721 (a) (2) (C),…

2Cases cited6 opinions

  1. Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
  2. William M. Bailey Co. v. CommissionerUnited States Tax Court · 1950
  3. Keystone Brass Works v. CommissionerUnited States Tax Court · 1949
  4. Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949
  5. Ohio Machine Tool Co. v. CommissionerUnited States Tax Court · 1952

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