Morris Plan Bank v. Commissioner
United States Board of Tax Appeals
The petitioner, operating under a perpetual charter, made a lump sum payment for an exclusive license to use "The Morris Plan," a copyrighted system for conducting a loan and investment business, in a certain territory, and other rights and benefits, including personal services rendered and to be rendered to it and expenses incurred in its organization.
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The petitioner, operating under a perpetual charter, made a lump sum payment for an exclusive license to use "The Morris Plan," a copyrighted system for conducting a loan and investment business, in a certain territory, and other rights and benefits, including personal services rendered and to be rendered to it and expenses incurred in its organization. In the absence of proof of what portion of the lump sum was paid for the license, but without deciding whether or not the license could be in any event treated as an exhaustible asset, the action of the respondent in refusing to allow any sum…
1Opinion of the Court
OPINION.
Sea well:
The respondent determined a deficiency of $359.85 in income tax against the petitioner for 1930 by disallowing, among other deductions, the sum of $2,500 claimed as a deduction for exhaustion of the cost of a license to use a copyrighted system of conducting a loan and investment business, known as “The Morris Plan.” Whether or not such action on the part of the respondent was proper is the only question before us for decision.
From the stipulation of facts, which constitutes the only evidence before us, it appears that the petitioner is an Ohio corporation existing under a…
2Cases cited3 opinions
- Malta Temple Ass'n v. CommissionerUnited States Board of Tax Appeals · 1929
- Norwich Pharmacal Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Surety Finance Co. of Tacoma v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by1 opinion
- Morris Plan Bank v. CommissionerUnited States Board of Tax Appeals · 1934