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VIBER COMPANY v. COMMISSIONER

Docket No. 749.

3 T.C.M. 1066 (1944)

Viber Company v. Commissioner.

United States Tax Court.

Entered October 11, 1944.

Attorney(s) appearing for the Case

Louis Lombardi, Esq., 510 W. Sixth St., Los Angeles, Calif., for the petitioner. Byron M. Coon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

HILL, Judge:

This proceeding involves a determination of income tax deficiencies for the years 1938, 1939 and 1940 in the amounts of $245.02, $92.57 and $325.55, respectively. The issue is whether the Commissioner erred in disallowing parts of the amounts deducted by the petitioner for those calendar years for amortization of patents. This turns on the question of what is the proper basis for those patents.

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