ROTORITE CORPORATION v. COMMISSIONER OF INTERNAL REV.

No. 7340.

117 F.2d 245 (1941)

ROTORITE CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

January 3, 1941.


Attorney(s) appearing for the Case

Raymond H. Schultz, Victor J. Voorheis, and David C. Kenyon, all of Chicago, Ill., for petitioner.

J. P. Wenchel and Chas. E. Lowery, both of Washington, D.C., for respondent.

Before EVANS, SPARKS, and TREANOR, Circuit Judges.


EVANS, Circuit Judge.

The payment of $65,797.06 to petitioner in the year 1935 has become the subject of uncompromising controversy between the Commissioner and taxpayer. Respondent contends that this sum was a part of petitioner's taxable income for 1935. Petitioner argues that the amount was paid as a part of the purchase price of patents which it owned.

More specifically the litigation is over a deficiency tax totalling $11,702.91 which was made up of the...

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