Russell T. Wing and Zoe E. Wing v. Commissioner of Internal Revenue

GARDNER, Circuit Judge.

Petitioner, referred to in the record as Wing, seeks a review of the decision of the Tax Court determining deficiencies in his income taxes for the years 1951, 1952 and 1953.

The facts are not in dispute and so far as here pertinent are substantially as follows. Petitioner invented a feed for fountain pens for which he filed an application for a patent in 1937, on which application patent issued in 1940. On January 24, 1938, he entered into a written agreement with the Parker Pen Company covering all existing inventions, in the agreement called “present inventions”, and…