Legal Opinion
Estate of G. R. Gowdey, Deceased, and Verna E. Gowdey, and Surviving Spouse v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided September 6, 1962No. 8495_1PublishedCited by 25 opinions
1Opinion of the Court
ALBERT V. BRYAN, Circuit Judge:
Capital gain or ordinary income * is the question arising here in classifying for taxation moneys received by the petitioner-taxpayers in these circumstances:
After a machine for freezing and dispensing a dairy product was patented, the “exclusive right and license to the use, manufacture, sale and distribution of all machines built under [the] patent” were acquired by one McCullough. The grant was limited to named States, including Virginia. The privilege was also given of awarding sublicenses “for territorial rights”. Grantee McCullough was to supply the…
2Cases cited19 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Crown Die & Tool Co. v. Nye Tool & MacHine WorksSupreme Court of the United States · 1923
- Cowell v. Springs Co.Supreme Court of the United States · 1879
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
14 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Bell Intercontinental Corporation v. The United StatesUnited States Court of Claims · 1967
- Vern H. Moberg and Reta N. Moberg v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962
- United States v. WernentinCourt of Appeals for the Eighth Circuit · 1965
- Theodore E. Moberg and Pauline Moberg v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Vern H. Moberg and Reta N. Moberg v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
20 more not listed; retrieve them via the Exa API.