Legal Opinion

Owens Bottle Co. v. Commissioner

United States Board of Tax Appeals

Decided November 5, 1927No. Docket No. 1033Published

1. A taxpayer possessing the sole and exclusive right and license to practice certain inventions and make and use certain machines covered by certain United States letters patent "and any and all patents which may result from the application for patents" recited in the license agreement "for and during the respective terms for which said patents are, or may be granted, in and throughout the United States * * * and use and sell the products of such processes and machines,…

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1. A taxpayer possessing the sole and exclusive right and license to practice certain inventions and make and use certain machines covered by certain United States letters patent "and any and all patents which may result from the application for patents" recited in the license agreement "for and during the respective terms for which said patents are, or may be granted, in and throughout the United States * * * and use and sell the products of such processes and machines, together with the right to grant to others sublicenses, or other rights under this agreement" is entitled to a deduction…

1Opinion of the Court

OWENS BOTTLE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Owens Bottle Co. v. Commissioner

Docket No. 1033.

United States Board of Tax Appeals

8 B.T.A. 1197; 1927 BTA LEXIS 2700;

November 5, 1927, Promulgated

1. A taxpayer possessing the sole and exclusive right and license to practice certain inventions and make and use certain machines covered by certain United States letters patent "and any and all patents which may result from the application for patents" recited in the license agreement "for and during the respective terms for which said patents are, or may be granted, in…

2Cases cited7 opinions

  1. Pullman's Palace Car Co. v. Central Transportation Co.Supreme Court of the United States · 1898
  2. Ray Consolidated Copper Co. v. United StatesSupreme Court of the United States · 1925
  3. Appeal of GrayUnited States Board of Tax Appeals · 1925
  4. Appeal of Service Recorder Co.United States Board of Tax Appeals · 1925
  5. Owens Bottle Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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