Legal Opinion

Lamb v. Commissioner

United States Tax Court

Decided August 2, 1966No. Docket No. 4509-64Published

Petitioner, who was an electrical engineer employed by IBM, voluntarily applied for the position of patent trainee in IBM's patent training program, a program designed to qualify eligible applicants for the position of patent attorney or agent with IBM. Petitioner was aware at the time of application for the position of patent trainee that he would be required, as a part of the program, to attend law school and maintain requisite progress toward obtaining an LL.B. degree.

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Petitioner, who was an electrical engineer employed by IBM, voluntarily applied for the position of patent trainee in IBM's patent training program, a program designed to qualify eligible applicants for the position of patent attorney or agent with IBM. Petitioner was aware at the time of application for the position of patent trainee that he would be required, as a part of the program, to attend law school and maintain requisite progress toward obtaining an LL.B. degree. Petitioner was accepted into the program, attended law school, received his degree, and was then employed as a patent…

1Opinion of the Court

Owen L. Lamb and Nancy G. Lamb, Petitioners, v. Commissioner of Internal Revenue, Respondent

Lamb v. Commissioner

Docket No. 4509-64

United States Tax Court

46 T.C. 539; 1966 U.S. Tax Ct. LEXIS 68;

August 2, 1966, Filed

Decision will be entered for the respondent.

Petitioner, who was an electrical engineer employed by IBM, voluntarily applied for the position of patent trainee in IBM's patent training program, a program designed to qualify eligible applicants for the position of patent attorney or agent with IBM. Petitioner was aware at the time of application for the position of patent trainee that…

2Cases cited5 opinions

  1. Sandt v. CommissionerCourt of Appeals for the Third Circuit · 1962
  2. Marlor v. CommissionerUnited States Tax Court · 1956
  3. Marlor v. CommissionerCourt of Appeals for the Second Circuit · 1958
  4. Lamb v. CommissionerUnited States Tax Court · 1966
  5. Williams v. United StatesDistrict Court, S.D. New York · 1965

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