Calso Co. v. Commissioner
United States Tax Court
The petitioner, over a period of time, loaned money to a partnership in which McCauley, the owner of all of its stock, was a partner. By 1941, the partnership had ceased all active operations and its only asset was its right to receive royalties payable under two license agreements covering patents owned in part by one Winslow, another of the partners, and his wife.
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The petitioner, over a period of time, loaned money to a partnership in which McCauley, the owner of all of its stock, was a partner. By 1941, the partnership had ceased all active operations and its only asset was its right to receive royalties payable under two license agreements covering patents owned in part by one Winslow, another of the partners, and his wife. By letter dated January 20, 1941, addressed to McCauley and signed by the partners, Winslow and another partnership of which he was a member were purportedly released from any personal liability of Winslow on the above…
1Opinion of the Court
The Calso Company, a corporation v. Commissioner.
Calso Co. v. Commissioner
Docket No. 27062.
United States Tax Court
1951 Tax Ct. Memo LEXIS 20; 10 T.C.M. (CCH) 1165; T.C.M. (RIA) 51349;
December 13, 1951
The petitioner, over a period of time, loaned money to a partnership in which McCauley, the owner of all of its stock, was a partner. By 1941, the partnership had ceased all active operations and its only asset was its right to receive royalties payable under two license agreements covering patents owned in part by one Winslow, another of the partners, and his wife. By letter dated January 20,…
2Cases cited1 opinion
- Clay Drilling Co. v. CommissionerUnited States Tax Court · 1946