Legal Opinion

Beausoleil v. Commissioner

United States Tax Court

Decided May 13, 1976No. Docket No. 1384-75Published

Held, a $ 1,600 Invention Achievement Award received by petitioner from his employer was additional compensation taxable as ordinary income under sec. 61(a)(1), I.R.C. 1954, and not a payment in consideration of the transfer of invention rights taxable as capital gain under sec. 1235, I.R.C. 1954.

1Opinion of the Court

William F. Beausoleil and Florence M. Beausoleil, Petitioners v. Commissioner of Internal Revenue, Respondent

Beausoleil v. Commissioner

Docket No. 1384-75

United States Tax Court

66 T.C. 244; 1976 U.S. Tax Ct. LEXIS 112; 190 U.S.P.Q. (BNA) 348;

May 13, 1976, Filed

Decision will be entered under Rule 155.

Held, a $ 1,600 Invention Achievement Award received by petitioner from his employer was additional compensation taxable as ordinary income under sec. 61(a)(1), I.R.C. 1954, and not a payment in consideration of the transfer of invention rights taxable as capital gain under sec. 1235, I.R.C. 1954.

Al…

2Cases cited12 opinions

  1. United States v. Dubilier Condenser CorpSupreme Court of the United States · 1933
  2. Blum v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1950
  3. Hofferbert, Collector of Internal Revenue v. BriggsCourt of Appeals for the Fourth Circuit · 1949
  4. Chilton v. CommissionerUnited States Tax Court · 1963
  5. Downs v. Comm'rUnited States Tax Court · 1968

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