Henry Vogt Mach. Co. v. Commissioner
United States Tax Court
In January 1985, P, a domestic manufacturer of heat recovery equipment, entered into an agreement (the Yamada agreement) with K, a Japanese corporation engaged in the manufacture and sale of combustion boiler generators, whereby P granted to K a license to use P's technical data (the Data) to manufacture and sell a specific type of generator within a defined geographical area (the Region). P concedes that all payments received under the Yamada agreement are taxable as…
Read the full summary
In January 1985, P, a domestic manufacturer of heat recovery equipment, entered into an agreement (the Yamada agreement) with K, a Japanese corporation engaged in the manufacture and sale of combustion boiler generators, whereby P granted to K a license to use P's technical data (the Data) to manufacture and sell a specific type of generator within a defined geographical area (the Region). P concedes that all payments received under the Yamada agreement are taxable as ordinary income. In late January or early February 1986, after being advised that long-term capital gain tax treatment could…
1Opinion of the Court
HENRY VOGT MACHINE COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Henry Vogt Mach. Co. v. Commissioner
Docket No. 21887-90
United States Tax Court
T.C. Memo 1993-371; 1993 Tax Ct. Memo LEXIS 380; 66 T.C.M. (CCH) 426;
August 19, 1993, Filed
Decision will be entered under Rule 155.
In January 1985, P, a domestic manufacturer of heat recovery equipment, entered into an agreement (the Yamada agreement) with K, a Japanese corporation engaged in the manufacture and sale of combustion boiler generators, whereby P granted to K a license to use P's technical data (the Data) to…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Bell Intercontinental Corporation v. The United StatesUnited States Court of Claims · 1967
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- E. I. Du Pont De Nemours and Company v. United StatesUnited States Court of Claims · 1961
19 more not listed; retrieve them via the Exa API.