Rakowsky v. Commissioner
United States Tax Court
Petitioner acquired in 1941, ownership of a contract for patent royalties and agreed to pay for such rights and for other property acquired at the same time, $ 50,000 to American Cyanamid Company. Petitioner executed his promissory note for this $ 50,000 payable to Cyanamid and due October 15, 1947. On May 1, 1942, petitioner assigned to Cyanamid his royalty contract as security for the $ 50,000 which he owed Cyanamid.
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Petitioner acquired in 1941, ownership of a contract for patent royalties and agreed to pay for such rights and for other property acquired at the same time, $ 50,000 to American Cyanamid Company. Petitioner executed his promissory note for this $ 50,000 payable to Cyanamid and due October 15, 1947. On May 1, 1942, petitioner assigned to Cyanamid his royalty contract as security for the $ 50,000 which he owed Cyanamid. On January 10, 1944, petitioner assigned to his daughter, Janis Velie, all of his right, title and interest in the patent royalty contract which he owned, subject, however, to…
1Opinion of the Court
Victor Rakowsky and Ella J. Rakowsky, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Rakowsky v. Commissioner
Docket No. 29509
United States Tax Court
17 T.C. 876; 1951 U.S. Tax Ct. LEXIS 29;
November 28, 1951, Promulgated
Decision will be entered for the respondent.
Petitioner acquired in 1941, ownership of a contract for patent royalties and agreed to pay for such rights and for other property acquired at the same time, $ 50,000 to American Cyanamid Company. Petitioner executed his promissory note for this $ 50,000 payable to Cyanamid and due October 15, 1947. On…
2Cases cited2 opinions
- Driscoll v. CommissionerUnited States Tax Court · 1944
- Rakowsky v. CommissionerUnited States Tax Court · 1951