Legal Opinion
Bloch v. United States
Court of Appeals for the Second Circuit
Decided November 21, 1952No. 22389_1PublishedCited by 21 opinions
1Opinion of the Court
AUGUSTUS N. HAND, Circuit Judge.
This is an appeal by the United States from a summary judgment for the plaintiff granting the latter’s claim for tax refunds for the years 1944, 1945 and 1946, D.C., 102 F.Supp. 457. The question raised by the appeal is whether an agreement gov*64erning certain patent rights, dated April 29, 1935, constituted a mere license agreement with the payment of royalties, or a sale. If the former, the plaintiff would clearly be taxable under § 211(a), 26 U.S.C.A.1
The taxpayer, a non-resident alien who was a citizen and resident of Germany, not engaged in business in the…
2Cases cited11 opinions
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Myers v. Comm'rUnited States Tax Court · 1946
- Commissioner of Internal Revenue v. HopkinsonCourt of Appeals for the Second Circuit · 1942
- Allen, Collector of Internal Revenue v. WernerCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
6 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- United States v. Eben H. Carruthers and Nancy CarruthersCourt of Appeals for the Ninth Circuit · 1955
- Kronner v. United StatesUnited States Court of Claims · 1953
- United States v. ZacksSupreme Court of the United States · 1963
- Daniel M. Cory and Margot Cory, His Wife, Petitioners-On-Review v. Commissioner of Internal Revenue, Respondent-On-ReviewCourt of Appeals for the Second Circuit · 1956
- Rollman v. CommissionerCourt of Appeals for the Fourth Circuit · 1957
16 more not listed; retrieve them via the Exa API.