Paxton v. Commissioner
United States Tax Court
Held, no portion of the payments received by petitioners under a license agreement for patents for inventions of one of petitioners which he transferred to a corporation in which he was the controlling stockholder was unstated interest within the provisions of sec. 483 because of the provisions of subsec. (f)(4) of that section.
1Opinion of the Court
opinion
Scott, Judge:
Respondent determined deficiencies in petitioners’ income taxes for tbe calendar years 1965 and 1966 in tbe amounts of $851.32 and $2,880.25, respectively.
Tbe only issue for decision is whether a portion of tbe payments received by petitioners during tbe years 1965 and 1966 under a license agreement whereby they disposed of substantially all rights in certain patents was unstated interest under tbe provisions of section 483, I.R.C. 1954.1
All of the facts have been stipulated and are found accordingly.
Petitioners at tbe time of tbe filing of tbe petition in this case…
2Cited by8 opinions
- Curtis T. Busse and Myrtle Busse v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1973
- Busse v. CommissionerUnited States Tax Court · 1972
- Busse v. United StatesUnited States Court of Claims · 1976
- Ransburg Corp. v. CommissionerUnited States Tax Court · 1979
- Busse v. CommissionerUnited States Tax Court · 1972
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