McCullough v. Comm'r
United States Tax Court
Petitioner I. J. McCullough and his brother owned 80 and 20 percent, respectively, of the stock of Tool Company. Subject to royalty rights of three other individuals, Sweetman and another were the owners of patent applications covering devices for the use of explosives for cutting and perforating pipe in wells, particularly oil and gas wells.
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Petitioner I. J. McCullough and his brother owned 80 and 20 percent, respectively, of the stock of Tool Company. Subject to royalty rights of three other individuals, Sweetman and another were the owners of patent applications covering devices for the use of explosives for cutting and perforating pipe in wells, particularly oil and gas wells. On October 1, 1947, Sweetman and his coowner granted an exclusive license to Tool Company to manufacture, sell, lease, rent, and use the devices covered in the patent applications and any and all patents which might be granted, subject, however, to the…
1Opinion of the Court
I. J. McCullough and Virginia S. McCullough, Petitioners, v. Commissioner of Internal Revenue, Respondent
McCullough v. Comm'r
Docket No. 66615
United States Tax Court
37 T.C. 1069; 1962 U.S. Tax Ct. LEXIS 174; 133 U.S.P.Q. (BNA) 422;
March 14, 1962, Filed
Decision will be entered under Rule 50.
Petitioner I. J. McCullough and his brother owned 80 and 20 percent, respectively, of the stock of Tool Company. Subject to royalty rights of three other individuals, Sweetman and another were the owners of patent applications covering devices for the use of explosives for cutting and perforating pipe in…
2Cases cited13 opinions
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Myers v. Comm'rUnited States Tax Court · 1946
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
- Kronner v. United StatesUnited States Court of Claims · 1953
- Osenbach v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
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