Hickman v. Comm'r
United States Tax Court
1. Held, that the transfer of November 6, 1947, by Irma Crall, administratrix, was intended to and did transfer to A. E. Hickman the entire, undivided one-half interest of the Estate of William R. Crall in a pending patent application and any patent granted thereunder; that said Irma Crall individually and A. E. Hickman, on the same date, intended to and did convey to a partnership which they formed as equal partners, their entire respective undivided one-half interests in…
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1. Held, that the transfer of November 6, 1947, by Irma Crall, administratrix, was intended to and did transfer to A. E. Hickman the entire, undivided one-half interest of the Estate of William R. Crall in a pending patent application and any patent granted thereunder; that said Irma Crall individually and A. E. Hickman, on the same date, intended to and did convey to a partnership which they formed as equal partners, their entire respective undivided one-half interests in said pending patent application and any patent granted thereunder; that, on January 3, 1949, the partnership (then…
1Opinion of the Court
Fisher, Judge:
Respondent determined income tax deficiencies and additions to tax in these consolidated proceedings as follows:
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The issues before the Court are: (1) Whether certain amounts received by petitioners in Docket Nos. 54014 and 54015, in connection with the transfer of a patent, are taxable as ordinary income or as long-term capital gains; and (2) whether the petitioners in Docket Nos. 54014 and 54015 are liable for additions to tax for the years 1951 and 1952 under section 294 (d) of the 1939 Internal Revenue Code. Petitioner has conceded the correctness of the income…
2Cases cited8 opinions
- Myers v. Comm'rUnited States Tax Court · 1946
- Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
- Dreymann v. Comm'rUnited States Tax Court · 1948
- Smith v. CommissionerUnited States Tax Court · 1953
3 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Bryan v. CommissionerUnited States Tax Court · 1959
- England v. CommissionerUnited States Tax Court · 1960
- E. I. Du Pont de Nemours & Co. v. United StatesUnited States Court of Claims · 1973
- Flanders v. United StatesDistrict Court, N.D. California · 1959
- Tomerlin Trust v. CommissionerUnited States Tax Court · 1986
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