Computer Sciences Corp. v. Commissioner
United States Tax Court
Held: (1) Computax was formed by petitioner as a wholly owned subsidiary and availed of with a view to the sale by petitioner to CCH of some of its stock prior to the time that a substantial amount of income had been realized from the use of the program for computer preparation of income tax returns developed by petitioner and transferred to Computax; (2) the program for preparation of income tax returns by computer developed by petitioner is intangible property produced by…
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Held: (1) Computax was formed by petitioner as a wholly owned subsidiary and availed of with a view to the sale by petitioner to CCH of some of its stock prior to the time that a substantial amount of income had been realized from the use of the program for computer preparation of income tax returns developed by petitioner and transferred to Computax; (2) the program for preparation of income tax returns by computer developed by petitioner is intangible property produced by petitioner; (3) production of the computer program for preparation of income tax returns had been completed by…
1Opinion of the Court
Scott, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the taxable year ended April 1,1966, in the amount of $694,248. Some of the issues have been disposed of by agreement of the parties, leaving for decision whether Computax Corp., petitioner’s wholly owned subsidiary engaged in the business of preparing State and Federal income tax returns, was a collapsible corporation within the meaning of section 341, I.R.C. 1954,1 so that petitioner’s gain on the sale of a controlling interest therein constitutes ordinary income.
FINDINGS OF FACT
Some of the facts have…
2Cases cited10 opinions
- Edward Weil and Dorothy Weil v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Temkin v. CommissionerUnited States Tax Court · 1961
- Riley v. CommissionerUnited States Tax Court · 1961
- Jacobson v. CommissionerCourt of Appeals for the Third Circuit · 1960
- John J. Goodrich v. Arnold C. Harmsen and Burke P. Lokey, Burke P. Lokey v. Arnold C. Harmsen and John J. GoodrichCourt of Customs and Patent Appeals · 1971
5 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Rolland L. King and Arlene P. King v. United StatesCourt of Appeals for the Fifth Circuit · 1981
- Spiridon Spireas v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2018
- Estate of Diecks v. CommissionerUnited States Tax Court · 1975
- Manassas Airport Industrial Park, Inc. v. CommissionerUnited States Tax Court · 1976
- Computer Sciences Corp. v. CommissionerUnited States Tax Court · 1974
6 more not listed; retrieve them via the Exa API.