Legal Opinion

Best Lock Corp. v. Commissioner

United States Tax Court

Decided March 26, 1959No. Docket Nos. 54550, 54567, 54571, 60805, 62155, 64623PublishedCited by 26 opinions

1. Best, an inventor of locks, in exchange for stock assigned patents and any improvements thereon devised by 1930 to Best, Inc., which in 1928 licensed Best Lock to manufacture under such patents or any improvements thereon owned by Best, Inc. In 1949 Best gave an exclusive license to Foundation which sublicensed Best Lock to manufacture a new lock under patents devised after 1930 for royalties to be paid to Foundation and Best.

Read the full summary

1. Best, an inventor of locks, in exchange for stock assigned patents and any improvements thereon devised by 1930 to Best, Inc., which in 1928 licensed Best Lock to manufacture under such patents or any improvements thereon owned by Best, Inc. In 1949 Best gave an exclusive license to Foundation which sublicensed Best Lock to manufacture a new lock under patents devised after 1930 for royalties to be paid to Foundation and Best. The new lock was not manufactured during the taxable years but patents involved extended protection against invasion of lock system and royalties were paid. Best…

1Opinion of the Court

Tegtjens, Judge:

These consolidated cases involve deficiencies in income tax as follows:

Docket Nos. 54567 and 64623, Feank E. Best and Emilia A. Best :

Year Deficiency

1949-$7,271.80

1950- 25,773.52

1951- 29,349.18

1952- 33, 326. 62

1953- 31,153.20

Docket Nos. 54550 and 60805, Best Lock Cokpobation :

Year Deficiency

1949_$13,707.14

1950_ 27,496. 74

1951_ 75, 691.77

1952_ 52, 688.23

Docket Nos. 54571 and 62155, The Best Foundation, Inc.:

Fiscal year ended June su Deficiency

1950_ $4, 854.18

1951_ 11, 333.35

1952_ 1953_ 13, 085.99 17,178.69

1954_ 13,422.10

The issues in the case of the individual petitioners are…

2Cases cited20 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Helvering v. HorstSupreme Court of the United States · 1940
  4. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  5. Better Business Bureau of Washington, D. C., Inc. v. United StatesSupreme Court of the United States · 1946

15 more not listed; retrieve them via the Exa API.

3Cited by26 opinions

  1. Rushing v. CommissionerUnited States Tax Court · 1969
  2. Green v. Comm'rUnited States Tax Court · 1984
  3. Dumaine Farms v. CommissionerUnited States Tax Court · 1980
  4. Best Universal Lock Co. v. CommissionerUnited States Tax Court · 1965
  5. Estate of Paxton v. CommissionerUnited States Tax Court · 1982

21 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API