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DETROIT GEAR & MACHINE CO. v. HELVERING

No. 6240.

75 F.2d 660 (1935)

DETROIT GEAR & MACHINE CO. v. HELVERING, Commissioner of Internal Revenue.

United States Court of Appeals for the District of Columbia.

Decided January 14, 1935.

Attorney(s) appearing for the Case

C. Clifton Owens, of Washington, D. C., for petitioner.

Frank J. Wideman, Assistant Attorney General, and Robert H. Jackson, Sewall Key, and Ellis N. Slack, all of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.

GRONER, Associate Justice.

Petitioner is a Michigan corporation whose principal business is the manufacture and sale of automobile parts and transmissions.

Some time prior to January 1, 1927, its general manager procured a license agreement with the owner of a patent, and in 1926 he and his associates caused two new corporations to be organized under the laws of Michigan for the purpose of exploiting the patent. The name of one was Norge Corporation and the...

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