Soffron v. Commissioner
United States Tax Court
Petitioners, each an owner of an undivided one-fourth interest in a patent, assigned it to a partnership in which each petitioner held a one-fourth interest. Held, the assignment was not a transfer of all substantial rights to the patent for the purposes of section 1235, I.R.C. 1954. Held, further, the amounts realized constitute ordinary income under the provisions of section 707(b)(2), I.R.C. 1954.
1Opinion of the Court
George N. and Lillian Soffron, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Soffron v. Commissioner
Docket Nos. 78117, 78118, 78119, 78120
United States Tax Court
35 T.C. 787; 1961 U.S. Tax Ct. LEXIS 221;
February 24, 1961, Filed
Decisions will be entered for the respondent.
Petitioners, each an owner of an undivided one-fourth interest in a patent, assigned it to a partnership in which each petitioner held a one-fourth interest. Held, the assignment was not a transfer of all substantial rights to the patent for the purposes of section 1235, I.R.C. 1954. Held, further, the…
2Cases cited4 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Soffron v. CommissionerUnited States Tax Court · 1961
- Stephen N. Soffron, Etc. v. S. W. Lovell & Company, Inc.Court of Appeals for the First Circuit · 1957