Borg & Beck Co. v. Commissioner
United States Board of Tax Appeals
1. The value of certain applications for patents paid into the petitioner for stock determined for invested capital purposes. 2. The amount at which intangible property acquired for stock may be included in the petitioner's invested capital determined. 3. The action of the respondent in reducing petitioner's invested capital on account of additional taxes for prior years sustained. 4. The value of certain patents determined for the purpose of computing the annual deduction…
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1. The value of certain applications for patents paid into the petitioner for stock determined for invested capital purposes. 2. The amount at which intangible property acquired for stock may be included in the petitioner's invested capital determined. 3. The action of the respondent in reducing petitioner's invested capital on account of additional taxes for prior years sustained. 4. The value of certain patents determined for the purpose of computing the annual deduction to which the petitioner is entitled for exhaustion. 5. The respondent's action in reducing the deduction taken by the…
1Opinion of the Court
*1002OPINION.
TRAmmiell:
The petitioner contends that the actual cash value of the four applications for patents acquired by it from the partnership at the time of organization in May, 1913, was at least $1,000,000. Considering all of the evidence submitted on this point we are of the opinion that the actual cash value of the applications was $700,000 and have so found as a fact. In arriving at this valuation we have given consideration to the testimony of witnesses, the facts known or reasonably anticipated at the basic date, and the close approximation of actual earnings to those anticipated. We…
2Cases cited11 opinions
- Gould v. GouldSupreme Court of the United States · 1917
- Norwood v. BakerSupreme Court of the United States · 1898
- Ward v. MarylandSupreme Court of the United States · 1871
- United States v. WoodwardSupreme Court of the United States · 1921
- Glasgow v. RowseSupreme Court of Missouri · 1869
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3Cited by18 opinions
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Firemen's Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- General Bancshares Corp. v. CommissionerUnited States Tax Court · 1962
- Commercial Inv. Trust Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Clark Thread Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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