Cold Metal Process Co. v. Commissioner

In 1945 a trustee which owned 151 shares of stock of a corporation acquired the remaining 1,849 shares in consideration of its promise to pay a total of $ 11,131,000 for the shares when funds became available. The corporation then filed a certificate of dissolution and assigned its assets to the trustee. Among the assets were claims for past infringement and royalties due on certain patents. Due to various orders in certain suits brought by the United States, moneys subsequently paid on these claims were paid into court. In 1949 the above suits were terminated and the moneys were paid over to…