Legal Opinion

Soffron v. Commissioner

United States Tax Court

Decided February 24, 1961No. Docket Nos. 78117, 78118, 78119, 78120Published

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

  1. Commissioner v. TowerSupreme Court of the United States · 1946
  2. Lusthaus v. CommissionerSupreme Court of the United States · 1946
  3. Soffron v. CommissionerUnited States Tax Court · 1961
  4. Stephen N. Soffron, Etc. v. S. W. Lovell & Company, Inc.Court of Appeals for the First Circuit · 1957

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