Texas Instruments v. Commissioner
United States Tax Court
P collected and processed seismic data and information, which was recorded on output tapes. P used those original tapes to produce copies that it sold to its nonexclusive customers, who used the licensed data and information on those copies for the purpose of exploring for resources on the Outer Continental Shelf.
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P collected and processed seismic data and information, which was recorded on output tapes. P used those original tapes to produce copies that it sold to its nonexclusive customers, who used the licensed data and information on those copies for the purpose of exploring for resources on the Outer Continental Shelf. Held, those original tapes were not property of a U.S. person used within the meaning of sec. 48(a)(2)(B)(vi), I.R.C., and P is not entitled to claim an investment tax credit thereon.
1Opinion of the Court
COHEN, Judge:
In our Memorandum Findings of Fact and Opinion filed this date, we separately discussed and decided three issues. The issue discussed in this opinion is whether petitioner's speculative data tapes were property described in section 48(a)(2)(B)(vi) and therefore eligible for the investment tax credit (ITC). The ITC was not claimed on petitioner's return. We address this issue separately because it has not been previously decided. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the…
2Cases cited14 opinions
- United States v. PriceSupreme Court of the United States · 1960
- E. I. Du Pont De Nemours and Company v. United StatesCourt of Appeals for the Third Circuit · 1970
- Walt Disney Productions v. United States of America, Walt Disney Productions v. United StatesCourt of Appeals for the Ninth Circuit · 1973
- Texas Instruments Incorporated, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Olin Bryant and Vanell Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
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3Cited by4 opinions
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- Texas Instruments v. CommissionerUnited States Tax Court · 1992