Sprague Electric Co. v. Commissioner
United States Tax Court
Petitioner has been an electronic components manufacturer since about 1926. During the years 1941 through 1945 it primarily manufactured condensers, resistors, and filters. Held, on the record presented petitioner has shown that some part of the income received from these items can be attributed to research and development in prior years within the meaning of section 721(a)(2)(C), I.R.C. 1939.
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies and overassessments in income, declared value excess profits tax, and excess profits taxes for the calendar years 1941 through 1945. The petition raised 20 issues on the basis of said determinations. Issues 2 through 20 relating to adjustments of gross income and deductions have been settled and the net tax effect of such settlement has been stipulated by the parties. The deficiencies determined by respondent and the overassessments claimed by petitioner are stipulated to remain in dispute as follows:
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The only…
2Cases cited13 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Soabar Co. v. CommissionerUnited States Tax Court · 1946
- Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
8 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Sprague Electric Company v. The Tax Court of the United StatesCourt of Appeals for the First Circuit · 1965
- Sprague Electric Company v. Tax Court of United StatesDistrict Court, D. Massachusetts · 1964
- Isis Windows, Inc. v. CommissionerUnited States Tax Court · 1963
- Stahl v. CommissionerUnited States Tax Court · 1963
- Challenger, Inc. v. CommissionerUnited States Tax Court · 1964
4 more not listed; retrieve them via the Exa API.