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ASSOCIATED PATENTEES, INC. v. COMMISSIONER

Docket No. 112051.

4 T.C. 979 (1945)

ASSOCIATED PATENTEES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 15, 1945.

Attorney(s) appearing for the Case

Howe P. Cochran, Esq., and Margaret F. Luers, Esq., for the petitioner.

Jonas M. Smith, Esq., for the respondent.

Memorandum findings of fact and opinion was entered in this proceeding on August 31, 1943. The deficiencies involved arose wholly from the disallowance by respondent of a deduction of $42,209.76 taken by petitioner for the calendar year 1940 as patent royalties paid in that year by it to four individuals. Our conclusion was that this payment was a capital expenditure by petitioner in the acquisition of the patents from those individuals...

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