Commercial Solvents Corp. v. Commissioner
United States Tax Court
1. Held, certain income received by petitioner during all the years here involved from a Japanese corporation (Kyowa) under an agreement dated August 6, 1951, was taxable to petitioner as ordinary income rather than as long-term capital gain. 2. In 1955 petitioner, on the accrual basis, entered into an agreement with a Canadian corporation (Northwest) to manage Northwest's business for an annual fee. The fee was to commence when commercial production of Northwest began.
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1. Held, certain income received by petitioner during all the years here involved from a Japanese corporation (Kyowa) under an agreement dated August 6, 1951, was taxable to petitioner as ordinary income rather than as long-term capital gain. 2. In 1955 petitioner, on the accrual basis, entered into an agreement with a Canadian corporation (Northwest) to manage Northwest's business for an annual fee. The fee was to commence when commercial production of Northwest began. The latter occurred on December 1, 1956. On December 31, 1956, petitioner had a fixed and unconditional right to receive its…
1Opinion of the Court
Commercial Solvents Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Commercial Solvents Corp. v. Commissioner
Docket Nos. 87814, 1574-62
United States Tax Court
42 T.C. 455; 1964 U.S. Tax Ct. LEXIS 98;
May 28, 1964, Filed
Decisions will be entered under Rule 50.
1. Held, certain income received by petitioner during all the years here involved from a Japanese corporation (Kyowa) under an agreement dated August 6, 1951, was taxable to petitioner as ordinary income rather than as long-term capital gain.
2. In 1955 petitioner, on the accrual basis, entered into an agreement with…
2Cases cited18 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936
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