Ramsey Accessories Mfg. Corp. v. Commissioner
United States Tax Court
1. Section 721 (a) (2) (C) -- Class of Income. -- Where a corporation develops patents and processes in prior years and then exploits the article produced thereby during the taxable year by manufacturing and selling it, using management salesmanship, plant, and equipment and other aids, not all of the gross income from the sale of the product can be classified as class (C) income from the development of the patents and processes, since some must be regarded as resulting from…
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1. Section 721 (a) (2) (C) -- Class of Income. -- Where a corporation develops patents and processes in prior years and then exploits the article produced thereby during the taxable year by manufacturing and selling it, using management salesmanship, plant, and equipment and other aids, not all of the gross income from the sale of the product can be classified as class (C) income from the development of the patents and processes, since some must be regarded as resulting from the other factors. 2. Section 721 (b) -- Attribution to Other Years. -- Amount of net abnormal income of the tax years…
1Opinion of the Court
OPINION.
Murdock, Judge:
Section 721 (a) (2) (C) provides that income resulting from development of patents or processes extending over a period of more than 12 months shall be held to be a separate class of income for the purpose of that section. The petitioner contends that all of its gross income from the sale of steel rings during 1940 and 1941 was of that class. It is obvious that not all of the income from the sale of steel rings during those years can be classified as resulting from development of patents or processes in prior years, because some of those profits must be attributed to…
2Cases cited2 opinions
- W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
- Producers Crop Improv. Asso. v. CommissionerUnited States Tax Court · 1946
3Cited by42 opinions
- Jarecki v. G. D. Searle & Co.Supreme Court of the United States · 1961
- Steel or Bronze Piston Ring Corp. v. CommissionerUnited States Tax Court · 1949
- William M. Bailey Co. v. CommissionerUnited States Tax Court · 1950
- Keystone Brass Works v. CommissionerUnited States Tax Court · 1949
- Pantasote Leather Co. v. CommissionerUnited States Tax Court · 1949
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