Independent Aetna Sprinkler Co. v. Commissioner
United States Board of Tax Appeals
1. Values of patent and a license agreement determined. 2. Petitioner is entitled to a deduction for exhaustion of the foregoing patent and license agreement computed upon the remaining life thereof when acquired. 3. The petitioner's invested capital for the years in question with respect to the patent and license agreement should be recomputed upon the basis of the values herein determined. 4. Respondent's action in reducing invested capital by the amount of income and…
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1. Values of patent and a license agreement determined. 2. Petitioner is entitled to a deduction for exhaustion of the foregoing patent and license agreement computed upon the remaining life thereof when acquired. 3. The petitioner's invested capital for the years in question with respect to the patent and license agreement should be recomputed upon the basis of the values herein determined. 4. Respondent's action in reducing invested capital by the amount of income and profits taxes for preceding taxable years approved under section 1207 of the Revenue Act of 1926. 5. For failure to adduce…
1Opinion of the Court
*532OPINION.
MoRRis:
The first, second, and third allegations of error urged by the petitioner relate to the inclusion in invested capital of the valúe of a patent, the value of what is denominated “ good will and organization,” and the value of a so-called license agreement and the deduc-tibility of exhaustion on said patent and agreement, based upon the remaining life thereof at the date of acquisition by the petitioner. The respondent contends that the petitioner has failed to establish the values contended for.
The petitioner alleges in its petition that it is entitled to a value of $200,000, as…
2Cited by1 opinion
- Independent Aetna Sprinkler Co. v. CommissionerUnited States Board of Tax Appeals · 1929