Legal Opinion

Electronic Mechanics, Inc. v. Commissioner

United States Tax Court

Decided October 10, 1950No. Docket No. 18899Published

Petitioner having worked for less than 12 months on a program of development initiated several years earlier by another corporation from which petitioner indirectly acquired its assets, held not entitled to relief under section 721 (a) (2) (C), Internal Revenue Code, requiring research or development "extending over a period of more than 12 months."

1Opinion of the Court

Electronic Mechanics, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Electronic Mechanics, Inc. v. Commissioner

Docket No. 18899

United States Tax Court

15 T.C. 489; 1950 U.S. Tax Ct. LEXIS 70;

October 10, 1950, Promulgated

Decision will be entered for the respondent.

Petitioner having worked for less than 12 months on a program of development initiated several years earlier by another corporation from which petitioner indirectly acquired its assets, held not entitled to relief under section 721 (a) (2) (C), Internal Revenue Code, requiring research or development "extending over…

2Cases cited4 opinions

  1. Stanton Brewery, Inc. v. CommissionerUnited States Tax Court · 1948
  2. Gallant v. Fashion Piece Dye WorksNew Jersey Court of Chancery · 1934
  3. P. Lorillard Co. v. PeperU.S. Circuit Court for the District of Eastern Missouri · 1895
  4. Electronic Mechanics, Inc. v. CommissionerUnited States Tax Court · 1950

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