Legal Opinion

Shepard v. Comm'r

United States Tax Court

Decided February 9, 1972No. Docket No. 3194-69Published

The petitioner, an inventor, developed a high-speed printer for use in conjunction with electronic computers. Thereafter he and the National Cash Register Co. entered into an agreement and two supplemental agreements under which such company obtained from him both a nonexclusive license with respect to two patents which related to certain aspects of the printer, and the technological know-how which was necessary to the manufacture of the printer.

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The petitioner, an inventor, developed a high-speed printer for use in conjunction with electronic computers. Thereafter he and the National Cash Register Co. entered into an agreement and two supplemental agreements under which such company obtained from him both a nonexclusive license with respect to two patents which related to certain aspects of the printer, and the technological know-how which was necessary to the manufacture of the printer. Held, that the amounts received by petitioner from the National Cash Register Co. during the years in question related solely to the technological…

1Opinion of the Court

Francis H. Shepard, Jr., and Margaret R. Shepard, Petitioners v. Commissioner of Internal Revenue, Respondent

Shepard v. Comm'r

Docket No. 3194-69

United States Tax Court

57 T.C. 600; 1972 U.S. Tax Ct. LEXIS 184; 173 U.S.P.Q. (BNA) 34;

February 9, 1972, Filed

Decision will be entered under Rule 50.

The petitioner, an inventor, developed a high-speed printer for use in conjunction with electronic computers. Thereafter he and the National Cash Register Co. entered into an agreement and two supplemental agreements under which such company obtained from him both a nonexclusive license with respect to…

2Cases cited12 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. United States v. Dubilier Condenser CorpSupreme Court of the United States · 1933
  3. Danielson v. CommissionerUnited States Tax Court · 1965
  4. Tabor v. . HoffmanNew York Court of Appeals · 1889
  5. Warner-Lambert Pharmaceutical Co. v. John J. Reynolds, Inc.District Court, S.D. New York · 1959

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