Smith, Inc. v. Commissioner
United States Tax Court
Held: Values of patents on various types of lawn and garden equipment and packaging devices determined. Held,further: Petitioner failed to prove that the failure of petitioner's liquidated subsidiary corporation to report depreciation recapture on its final return was not due to negligence or intentional disregard of rules and regulations. Imposition of addition to tax under sec. 6653(a), I.R.C. 1954, upheld.
1Opinion of the Court
R. M. SMITH, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Smith, Inc. v. Commissioner
Docket No. 478-74.
United States Tax Court
T.C. Memo 1977-23; 1977 Tax Ct. Memo LEXIS 422; 36 T.C.M. (CCH) 97; T.C.M. (RIA) 770023;
January 31, 1977, Filed
Held: Values of patents on various types of lawn and garden equipment and packaging devices determined.
Held,further: Petitioner failed to prove that the failure of petitioner's liquidated subsidiary corporation to report depreciation recapture on its final return was not due to negligence or intentional disregard of rules and regulations.…
2Cases cited23 opinions
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Patterson v. KentuckySupreme Court of the United States · 1879
- Courtney v. CommissionerUnited States Tax Court · 1957
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Copperhead Coal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959
18 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Deseret Management Corporation v. United StatesUnited States Court of Federal Claims · 2013