Juda v. Commissioner
United States Tax Court
C is a limited partnership formed for the purpose of developing and commercially exploiting specific products and product concepts. C acquired rights in three patents from unrelated inventors subject to conditions requiring C to create companies and transfer the patent rights to the companies. C then sold the three patents to three other limited partnerships which C had organized.
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C is a limited partnership formed for the purpose of developing and commercially exploiting specific products and product concepts. C acquired rights in three patents from unrelated inventors subject to conditions requiring C to create companies and transfer the patent rights to the companies. C then sold the three patents to three other limited partnerships which C had organized. Held: C did not acquire all substantial rights to the patents and therefore did not subsequently transfer all substantial rights. Accordingly, gains from the sales may not be treated as capital gains under sec.…
1Opinion of the Court
Walter and Renee Juda, Petitioners v. Commissioner of Internal Revenue, Respondent
Juda v. Commissioner
Docket No. 10026-84
United States Tax Court
90 T.C. 1263; 1988 U.S. Tax Ct. LEXIS 82; 90 T.C. No. 83;
June 27, 1988; As amended July 8, 1988 June 27, 1988, Filed
Decision will be entered for the respondent.
C is a limited partnership formed for the purpose of developing and commercially exploiting specific products and product concepts. C acquired rights in three patents from unrelated inventors subject to conditions requiring C to create companies and transfer the patent rights to the companies.…
2Cases cited13 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Hildreth v. MastorasSupreme Court of the United States · 1921
- King v. CommissionerUnited States Tax Court · 1987
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