Legal Opinion
Gregg v. Commissioner
United States Tax Court
Decided May 13, 1952No. Docket Nos. 26349, 26350PublishedCited by 4 opinions
1Opinion of the Court
OPINION.
Van Fossan, Judge:
We have three issues presented in these proceedings. The first is common to both cases and involves the treatment to be given to certain sums received by both petitioners during the taxable years here under review. Specifically, the question is whether such amounts are to be characterized as ordinary income taxable under section 22 (a) of the Code1 or as capital gains derived from the sale of a patent and taxable pursuant to sections 117 (a) and (b), Internal Revenue Code.2
During the year 1942 petitioners had pending before the United States Patent Office an…
2Cases cited13 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Gayler v. WilderSupreme Court of the United States · 1851
- United States v. General Electric Co.Supreme Court of the United States · 1926
- Crown Die & Tool Co. v. Nye Tool & MacHine WorksSupreme Court of the United States · 1923
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3Cited by4 opinions
- Rollman v. CommissionerCourt of Appeals for the Fourth Circuit · 1957
- Rollman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
- Finn H. Magnus and Elsie A. Magnus v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Gregg v. Comm'rUnited States Tax Court · 1952