United States Mineral Prods. Co. v. Comm'r
United States Tax Court
Petitioner is a United States corporation engaged in the manufacture and sale within this country of sprayed-insulation products. Prior to 1959 its products were sold to a distributor in Canada who applied the products and sold to other applicators.
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Petitioner is a United States corporation engaged in the manufacture and sale within this country of sprayed-insulation products. Prior to 1959 its products were sold to a distributor in Canada who applied the products and sold to other applicators. In order to compete against Canadian products, petitioner organized a wholly owned subsidiary under Canadian law and transferred to it in March 1959 certain rights relating to patents, trademarks, and know-how which comprised the collective technical and production knowledge essential to petitioner's business. Through its own manufacturing and…
1Opinion of the Court
United States Mineral Products Company, Petitioner v. Commissioner of Internal Revenue, Respondent
United States Mineral Prods. Co. v. Comm'r
Docket No. 4733-66
United States Tax Court
52 T.C. 177; 1969 U.S. Tax Ct. LEXIS 138; 162 U.S.P.Q. (BNA) 480;
May 5, 1969, Filed
Decision will be entered under Rule 50.
Petitioner is a United States corporation engaged in the manufacture and sale within this country of sprayed-insulation products. Prior to 1959 its products were sold to a distributor in Canada who applied the products and sold to other applicators. In order to compete against Canadian products,…
2Cases cited33 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Watson v. CommissionerSupreme Court of the United States · 1953
- Williams v. McGowanCourt of Appeals for the Second Circuit · 1945
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
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