R. T. French Co. v. Commissioner
United States Tax Court
1. Held: Royalty payments by T corp. to an affiliated foreign company were made pursuant to licensing arrangements such as would have been entered into by parties dealing at arm's length.
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1. Held: Royalty payments by T corp. to an affiliated foreign company were made pursuant to licensing arrangements such as would have been entered into by parties dealing at arm's length. The royalty expenses were therefore deductible under sec. 162(a) of the 1954 Code, and the Commissioner's disallowance of such deductions under the claimed authority of sec. 482 of the Code was improper. 2. T concedes that income must be imputed to it by reason of the free use by its foreign "brother-sister" affiliates of certain intangible assets owned by T. T will never receive actual payment from the…
1Opinion of the Court
The R. T. French Company, Petitioner v. Commissioner of Internal Revenue, Respondent
R. T. French Co. v. Commissioner
Docket Nos. 5026-70, 5027-70, 5028-70
United States Tax Court
60 T.C. 836; 1973 U.S. Tax Ct. LEXIS 63; 60 T.C. No. 89;
September 6, 1973, Filed
Decisions will be entered under Rule 50.
1. Held: Royalty payments by T corp. to an affiliated foreign company were made pursuant to licensing arrangements such as would have been entered into by parties dealing at arm's length. The royalty expenses were therefore deductible under sec. 162(a) of the 1954 Code, and the Commissioner's…
2Cases cited41 opinions
- Brulotte v. Thys Co.Supreme Court of the United States · 1964
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Ach v. CommissionerUnited States Tax Court · 1964
- Estate of Beck v. Comm'rUnited States Tax Court · 1971
- Rushing v. CommissionerUnited States Tax Court · 1969
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