Potter v. Comm'r
United States Tax Court
1. Petitioner by one instrument created irrevocable trusts for his wife and two minor children. He transferred to the trusts the full and exclusive right, title, and interest in and to a certain patent application and any and all patents issued thereon. Coincidentally with the creation of the trusts, the trustees entered into a nonexclusive license agreement with petitioner to make, use, and sell the article covered in the application at a graduated royalty rate.
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1. Petitioner by one instrument created irrevocable trusts for his wife and two minor children. He transferred to the trusts the full and exclusive right, title, and interest in and to a certain patent application and any and all patents issued thereon. Coincidentally with the creation of the trusts, the trustees entered into a nonexclusive license agreement with petitioner to make, use, and sell the article covered in the application at a graduated royalty rate. The trusts were to continue until the children reached their majority. One child was born about the time the trusts were created.…
1Opinion of the Court
John T. Potter, Petitioner, v. Commissioner of Internal Revenue, Respondent
Potter v. Comm'r
Docket No. 52506
United States Tax Court
27 T.C. 200; 1956 U.S. Tax Ct. LEXIS 52;
October 31, 1956, Filed
Decision will be entered under Rule 50.
1. Petitioner by one instrument created irrevocable trusts for his wife and two minor children. He transferred to the trusts the full and exclusive right, title, and interest in and to a certain patent application and any and all patents issued thereon. Coincidentally with the creation of the trusts, the trustees entered into a nonexclusive license agreement with…
2Cases cited19 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Fuller v. CommissionerUnited States Tax Court · 1953
- Limericks, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
- Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
- Brown v. Commissioner of Internal Revenue (Two Cases)Court of Appeals for the Third Circuit · 1950
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