Legal Opinion

Whitelite Electric Co. v. Commissioner

United States Board of Tax Appeals

Decided January 27, 1930No. Docket No. 28472PublishedCited by 4 opinions

The Commissioner correctly included depreciated cost of certain patents in his determination of the basic cost of a mixed body of assets sold in the taxable years by an affiliated group of which the petitioner was the parent corporation.

1Opinion of the Court

*936OPINION.

Lansdon:

None of the facts material to the sole issue here are in dispute. The parties agree that the patents in question cost the Tungsten Lamp Co. $75,000, and that such patents, standing alone, had no value in 1923. In computing its gross income in the taxable year the petitioner included the amount of $75,000 in its basis for. computing profit on the sale of its assets as the cost of such patents. The Commissioner accepted this amount as original cost, but computed accrued depreciation in the amount of $46,804.96, which he added to gross income. The amount of accrued depreciation…

2Cited by4 opinions

  1. Kaspar v. Comm'rUnited States Tax Court · 1976
  2. Richards v. CommissionerUnited States Tax Court · 1943
  3. Whitelite Electric Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  4. Young v. CommissionerUnited States Tax Court · 1957

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