Emory v. Commissioner
United States Tax Court
Petitioner, Burde, and Weiss each held a one-third interest in a bath oil formula which petitioner invented. They transferred said formula to a partnership consisting of petitioner, Burde's wife, and Weiss' wife, in exchange for a royalty.
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Petitioner, Burde, and Weiss each held a one-third interest in a bath oil formula which petitioner invented. They transferred said formula to a partnership consisting of petitioner, Burde's wife, and Weiss' wife, in exchange for a royalty. The assets of the transferee partnership were subsequently transferred to a corporation and petitioner, Burde's wife, and Weiss' wife received 80 percent of the transferee corporation's outstanding capital stock; the transferee corporation also assumed the royalty agreement. Held, the transfer of the bath oil formula to the partnership was not a transfer of…
1Opinion of the Court
Martin F. Emory and Nan Emory, Petitioners v. Commissioner of Internal Revenue, Respondent
Emory v. Commissioner
Docket No. 4455-63
United States Tax Court
47 T.C. 710; 1967 U.S. Tax Ct. LEXIS 125;
March 31, 1967, Filed
Decision will be entered for the respondent.
Petitioner, Burde, and Weiss each held a one-third interest in a bath oil formula which petitioner invented. They transferred said formula to a partnership consisting of petitioner, Burde's wife, and Weiss' wife, in exchange for a royalty. The assets of the transferee partnership were subsequently transferred to a corporation and…
2Cases cited4 opinions
- Max A. Burde and Berthe C. Burde v. Commissioner of Internal Revenue, Bernard Weiss and Peggy S. Weiss v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Burde v. CommissionerUnited States Tax Court · 1964
- Soffron v. CommissionerUnited States Tax Court · 1961
- Emory v. CommissionerUnited States Tax Court · 1967