GENERAL ANILINE & FILM CORP. v. COM'R OF INTERNAL REV.

No. 73.

139 F.2d 759 (1944)

GENERAL ANILINE & FILM CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

January 3, 1944.


Attorney(s) appearing for the Case

Martin Saxe and Roger H. Anderson, both of New York City, and Edward F. Colladay and Wilton H. Wallace, both of Washington, D. C. (W. Brown Morton and W. Peters Blanc, both of New York City, of counsel), for petitioner.

Samuel O. Clark, Jr., Sewall Key, Helen R. Carloss, and Newton K. Fox, all of Washington, D. C., for respondent.

Before L. HAND, CHASE, and FRANK, Circuit Judges.


FRANK, Circuit Judge.

We incline strongly to the belief that title to the patents passed to petitioner. Littlefield v. Perry, 21 Wall. 205, 22 L. Ed. 577.2 However, the passing of title does not preclude the existence of royalties. But the crucial question here is whether the royalties are income to I. G. within the meaning of this tax statute. Under one of the contracts, a lump sum payment was made for the assignment. Such a payment is...

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