Goodell-Pratt Co. v. Commissioner
United States Board of Tax Appeals
The deduction, concurrently, as operating expenses, of expenditures made in the development of patents, processes, etc., does not bar their restoration to surplus upon a clear showing that they were in fact capital expenditures. Appeals of Gilliam Mfg. Co.,1 B.T.A. 967, and Union Metal .mfg. Co.,1 B.T.A. 395, cited and approved.
1Opinion of the Court
*32OPINION.
Korner, Chairman:
The only question presented by the record in this appeal is whether or not the taxpayer may include in invested capital for the years 1917, 1918, and 1919 the amount of $280,513.26 expended during the years 1909 to 1916, inclusive, for development of patents, secret processes, methods of manufacture, special machinery and new tools, foreign markets, etc., charged to expense concurrently with the transactions and deducted from gross income for income-tax purposes in those years.
The Commissioner admits that the amount involved was expended for the purposes stated, but…
2Cases cited1 opinion
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
3Cited by13 opinions
- Hart-Bartlett-Sturtevant Grain Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1950
- Canning v. CommissionerUnited States Board of Tax Appeals · 1933
- American Seating Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Briarcliff Candy Corp. v. CommisionerUnited States Tax Court · 1972
- Canning v. CommissionerUnited States Board of Tax Appeals · 1933
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