Newton Insert Co. v. Commissioner
United States Tax Court
Petitioner's corporate transferor, Newton, entered into an agreement in 1961 with City of Hope, a California nonprofit corporation, whereby City of Hope granted Newton in return for a percentage of sales the exclusive rights to make, use, and sell patented products for the entire life of the patents.
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Petitioner's corporate transferor, Newton, entered into an agreement in 1961 with City of Hope, a California nonprofit corporation, whereby City of Hope granted Newton in return for a percentage of sales the exclusive rights to make, use, and sell patented products for the entire life of the patents. These patents had been transferred to City of Hope by Neuschotz, the inventor and owner of the patents and major shareholder of Newton until 1965. Newton entered into an exclusive license agreement in 1966 with Neuschotz, covering other patents in return for a percentage of annual sales of the…
1Opinion of the Court
Newton Insert Company, Transferor, and Tridair Industries, Transferee, Petitioners v. Commissioner of Internal Revenue, Respondent
Newton Insert Co. v. Commissioner
Docket No. 7786-70
United States Tax Court
61 T.C. 570; 1974 U.S. Tax Ct. LEXIS 159; 61 T.C. No. 62;
January 30, 1974, Filed
Decision will be entered under Rule 155.
Petitioner's corporate transferor, Newton, entered into an agreement in 1961 with City of Hope, a California nonprofit corporation, whereby City of Hope granted Newton in return for a percentage of sales the exclusive rights to make, use, and sell patented products for the…
2Cases cited22 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Myers v. Comm'rUnited States Tax Court · 1946
- Virginian Hotel Corporation v. Helvering, Commissioner of Internal RevenueSupreme Court of the United States · 1943
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
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