Legal Opinion

Hagner v. Commissioner

United States Tax Court

Decided April 19, 1950No. Docket Nos. 16352, 16353Published

Petitioner, an inventor, was the owner of 75 per cent of the stock and president of a corporation whose only assets were patents which were classified by the Government as secret and placed on the restricted list, the owner not being permitted to use them or license their use by others except by permission of the Government.

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Petitioner, an inventor, was the owner of 75 per cent of the stock and president of a corporation whose only assets were patents which were classified by the Government as secret and placed on the restricted list, the owner not being permitted to use them or license their use by others except by permission of the Government. As a result, the corporation was without money to pay petitioner's salary during the period 1941 to 1943, inclusive, although during that time petitioner was active in the interest of the corporation, in work for the United States Navy in an endeavor to adapt the patented…

1Opinion of the Court

Frederick H. Hagner, Petitioner, v. Commissioner of Internal Revenue, Respondent. Celina C. Hagner, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hagner v. Commissioner

Docket Nos. 16352, 16353

United States Tax Court

14 T.C. 643; 1950 U.S. Tax Ct. LEXIS 222;

April 19, 1950, Promulgated

Decisions will be entered under Rule 50.

Petitioner, an inventor, was the owner of 75 per cent of the stock and president of a corporation whose only assets were patents which were classified by the Government as secret and placed on the restricted list, the owner not being permitted to use them or…

2Cases cited3 opinions

  1. Kenny v. CommissionerUnited States Tax Court · 1945
  2. Dean v. CommissionerUnited States Tax Court · 1948
  3. Hagner v. CommissionerUnited States Tax Court · 1950

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