Snow v. Commissioner
United States Tax Court
Snow, an executive in a large corporation, invested money and gave advisory services in three limited partnerships formed in 1965 and 1966, each to carry on research and experimentation upon a particular invention with a view to profit. In 1966 two of the inventions were held for licensing to manufacturers but none were so licensed in that year.
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Snow, an executive in a large corporation, invested money and gave advisory services in three limited partnerships formed in 1965 and 1966, each to carry on research and experimentation upon a particular invention with a view to profit. In 1966 two of the inventions were held for licensing to manufacturers but none were so licensed in that year. The third invention, a trash burner, was not sufficiently developed to be ready for sale or licensing in 1966. The partnership developing this invention had no income in 1966 but reported a net loss by reason of a deduction claimed under sec. 174(a),…
1Opinion of the Court
Bruce, Judge:
Respondent determined a deficiency of $6,247 in the income tax of the petitioners for the calendar year 1966. Edwin A. Snow was a member of a partnership which reported a net loss for 1966 by reason of a deduction claimed under section 174,1.R.C. 1954, for expenditures for research and experimentation. Respondent disallowed the pro rata share of such loss claimed by the petitioners. The sole issue for decision is whether such expenses are properly deductible. Some facts are stipulated.
FINDINGS OF FACT
The stipulation of facts and the exhibits attached thereto are incorporated by…
2Cases cited18 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Frank v. CommissionerUnited States Tax Court · 1953
- Polachek v. CommissionerUnited States Tax Court · 1954
- Koons v. CommissionerUnited States Tax Court · 1961
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3Cited by25 opinions
- Snow v. CommissionerSupreme Court of the United States · 1974
- Goodwin v. CommissionerUnited States Tax Court · 1980
- Drobny v. CommissionerUnited States Tax Court · 1986
- Green v. Comm'rUnited States Tax Court · 1984
- Levin v. CommissionerUnited States Tax Court · 1986
20 more not listed; retrieve them via the Exa API.