Graham v. Commissioner
United States Tax Court
In 1970, petitioner Robert M. Graham's former wife transferred a secret formula to a corporation controlled by them. In return, the corporation agreed to pay her "royalties" based upon proceeds derived from the sale of products using the formula.
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In 1970, petitioner Robert M. Graham's former wife transferred a secret formula to a corporation controlled by them. In return, the corporation agreed to pay her "royalties" based upon proceeds derived from the sale of products using the formula. Joint Federal income tax returns were filed by the couple for 1972, 1973, and 1974. For 1972, she paid a deficiency in income taxes determined with respect to receipts from the corporation and filed a suit for refund in the District Court. That court held that, within the meaning of sec. 1239(a), I.R.C. 1954, (1) the transaction with the corporation…
1Opinion of the Court
Robert M. Graham, Petitioner v. Commissioner of Internal Revenue, Respondent; Robert M. Graham and Betty Jo Graham, Petitioners v. Commissioner of Internal Revenue, Respondent
Graham v. Commissioner
Docket Nos. 6709-77, 9977-78
United States Tax Court
76 T.C. 853; 1981 U.S. Tax Ct. LEXIS 121;
May 27, 1981, Filed
Decision will be entered for the petitioners.
In 1970, petitioner Robert M. Graham's former wife transferred a secret formula to a corporation controlled by them. In return, the corporation agreed to pay her "royalties" based upon proceeds derived from the sale of products using the formula.…
2Cases cited17 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Blonder-Tongue Laboratories, Inc. v. University of Illinois FoundationSupreme Court of the United States · 1971
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