Legal Opinion
Sprague Electric Company v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided April 28, 1964No. 6155PublishedCited by 1 opinion
1Opinion of the Court
ALDRICH, Circuit Judge.
In this proceeding to review a decision of the Tax Court taxpayer, Sprague Electric Company, seeks to minimize or avoid impositions under the Excess Profits Tax Act of 1940 by proof that certain income was to be excluded as “abnormal” because attributable to “ * * * research, or development of tangible property, patents, formulae, or processes * * * ” carried on during pre-tax years. 1939 I.R.C. § 721(a) (2) (C). As to some items it was successful, but as to one, known as networks, it was not. At the threshold in this court respondent Commissioner moves to dismiss the…
2Cases cited18 opinions
- Arkansas Motor Coaches, Limited, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
- Industrial Trust Co. v. Commissioner of Internal Rev.Court of Appeals for the First Circuit · 1947
- Packer Pub. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1954
- Green Spring Dairy, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Stimson Mill Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1947
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3Cited by1 opinion
- Sprague Electric Company v. The Tax Court of the United StatesCourt of Appeals for the First Circuit · 1965