Legal Opinion

Big Four Industries, Inc. v. Commissioner

United States Tax Court

Decided September 30, 1963No. Docket No. 94780Published

Award received in patent infringement litigation held to include, in addition to compensation for lost profits which is conceded to be taxable as ordinary income, (a) reimbursement for litigation expenses, which is taxable as ordinary income, and (b) compensation for injury to capital structure and goodwill which is taxable as capital gain to the extent that such compensation exceeds basis.

1Opinion of the Court

Big Four Industries, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Big Four Industries, Inc. v. Commissioner

Docket No. 94780

United States Tax Court

40 T.C. 1055; 1963 U.S. Tax Ct. LEXIS 45;

September 30, 1963, Filed

Decision will be entered under Rule 50.

Award received in patent infringement litigation held to include, in addition to compensation for lost profits which is conceded to be taxable as ordinary income, (a) reimbursement for litigation expenses, which is taxable as ordinary income, and (b) compensation for injury to capital structure and goodwill which is taxable as…

2Cases cited10 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Raytheon Production Corp. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1944
  3. Durkee v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1947
  4. Mathey v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1949
  5. Sager Glove Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962

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