Legal Opinion

Union Paper Co. v. Commissioner

United States Board of Tax Appeals

Decided December 31, 1927No. Docket No. 6402PublishedCited by 3 opinions

Market value of patent application at March 1, 1913, for the purpose of exhaustion of a patent subsequently granted thereon not determinable from the evidence.

1Opinion of the Court

*1013OPINION.

Smith :

The petitioner contends that the patent application which it owned on March 1, 1913, and for which the patent was issued by the United States Patent Office the following year, had a definite minimum value at March 1,1913, of $35,000, and that for each of the taxable years 1917 and 1918 it is entitled to a deduction on account of the exhaustion of the patent equal to one-seventeenth of the March *10141, 1913, value of the patent application. The respondent contends that the patent application had no determinable value at March 1, 1913, and that since the patent was acquired by the…

2Cited by3 opinions

  1. B. F. Sturtevant Co. v. United StatesDistrict Court, D. Massachusetts · 1937
  2. Hershey Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  3. Union Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1927

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