Legal Opinion
McCullough v. Commissioner
United States Tax Court
Decided March 14, 1962No. Docket No. 66615PublishedCited by 1 opinion
1Opinion of the Court
OPINION.
TuRnee, Judge:
It is the position of the petitioner that he acquired an interest in the jet perforator patents from Sweetman on August 4, 1948; that he sold the interest so acquired to Tool Company on December 28, 1950; and that the payments received during the taxable years under the 1950 agreement constituted long-term capital gains from such sale.
If, however, the license agreement of October 1, 1947, had effected a sale of the patents to Tool Company, as respondent contends, petitioner in 1948 acquired no ownership in the patents and could not and did not sell any interest therein…
2Cases cited11 opinions
- Lusthaus v. CommissionerSupreme Court of the United States · 1946
- Myers v. Comm'rUnited States Tax Court · 1946
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
- Kronner v. United StatesUnited States Court of Claims · 1953
- Osenbach v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
6 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- McCullough v. Comm'rUnited States Tax Court · 1962