Service Recorder Co. v. Commissioner
United States Board of Tax Appeals
1. A license for the use of a patent during its life is subject to exhaustion in the same manner as the patent. 2. Where such license has been acquired for stock, exhaustion should be computed upon its actual cash value, rather than upon the par value of the stock issued therefor.
1Opinion of the Court
APPEAL OF THE SERVICE RECORDER CO.
Service Recorder Co. v. Commissioner
Docket No. 2201.
United States Board of Tax Appeals
2 B.T.A. 96; 1925 BTA LEXIS 2541;
June 19, 1925, Decided Submitted May 11, 1925.
1. A license for the use of a patent during its life is subject to exhaustion in the same manner as the patent.
2. Where such license has been acquired for stock, exhaustion should be computed upon its actual cash value, rather than upon the par value of the stock issued therefor.
Stephen G. Rusk, C.P.A., for the taxpayer.
M. N. Fisher, Esq., for the Commissioner.
SMITH
Before JAMES, LITTLETON, and…
2Cases cited2 opinions
- Union Metal Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- Appeal of Service Recorder Co.United States Board of Tax Appeals · 1925