Sheffield Dentifrice Co. v. Commissioner
United States Board of Tax Appeals
1. In 1919 the petitioner abandoned the manufacture and sale of a trade-marked alcoholic cordial known as "Creme Yvette" on account of prohibition legislation. The cost of this trade-mark upon which this business depended was $46,875. In the audit of its income-tax return for 1919, the Commissioner allowed as a deduction from gross income $6,818.18 as obsolescence of the value of the trade-mark.
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1. In 1919 the petitioner abandoned the manufacture and sale of a trade-marked alcoholic cordial known as "Creme Yvette" on account of prohibition legislation. The cost of this trade-mark upon which this business depended was $46,875. In the audit of its income-tax return for 1919, the Commissioner allowed as a deduction from gross income $6,818.18 as obsolescence of the value of the trade-mark. Held, that the petitioner is entitled to deduct from the gross income of 1919 as a loss sustained the entire cost of the trade-mark, namely, $46,875. 2. In 1919 the petitioner and the New England…
1Opinion of the Court
*879OPINION.
Smith:
1. In its petition the petitioner alleges that the Commissioner has determined that the cost of the trade-mark “ Creme Yvette,” upon which a profitable branch of its business depended, was $46,-875. This is admitted by the answer of the respondent. The evidence indicates that this was acquired by the Wo Sheffield brothers, who owned all of the capital stock of the petitioner and of the New England Collapsible Tube Co. in equal interest and that they turned over this business to the Sheffield Dentifrice Co. for a nominal consideration. The March 1, 1913, value of the trade-mark…
2Cited by1 opinion
- Sheffield Dentifrice Co. v. CommissionerUnited States Board of Tax Appeals · 1928