Elliott v. Commissioner
United States Board of Tax Appeals
Held, payments made to the taxpayer of an agreed percentage of rentals, collected by his licensee, for use of an invention of which the taxpayer was part owner, are taxable income to him for the year received.
1Opinion of the Court
opinion.
Lansdon :
These consolidated appeals have been submitted for our determination upon a stipulation of facts which we adopt and make a *6part of this decision by reference. In Docket No. 32832, the petitioner appeals from the respondent’s determination of a deficiency in income tax for 1924 of $28,930.56, and in Docket No. 42454 a similar deficiency of $911.32 for 1925 is challenged.
Prior to May 10, 1924, and during all of the years involved, the petitioner was vice president and business manager of the Palmer School of Chiropractic, a corporation, located at Davenport, Iowa. At some prior…
2Cases cited2 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Shepard v. Northwestern Life Ins. Co.U.S. Circuit Court for the District of Eastern Michigan · 1889
3Cited by2 opinions
- Elliott v. CommissionerUnited States Board of Tax Appeals · 1931
- Evins v. CommissionerUnited States Board of Tax Appeals · 1931