1. Home
  2. Browse Decisions
  3. F.2d
  4. 269 F.2d
  5. 269 F.2d 89 (1959)
 

YOUNG v. C. I. R.

No. 176, Docket 25348.

269 F.2d 89 (1959)

Arthur M. and Ruth F. YOUNG, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided July 13, 1959.

Attorney(s) appearing for the Case

Stephen P. Duggan, Jr., New York City (William J. Manning, Donald Oresman and Simpson Thacher & Bartlett, New York City, on the brief), for petitioners.

Grant W. Wiprud, Dept. of Justice, Washington, D. C. (Howard A. Heffron, Acting Asst. Atty. Gen., Lee A. Jackson and Harry Baum, Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before MEDINA, LUMBARD and WATERMAN, Circuit Judges.

LUMBARD, Circuit Judge.

The sole question before us is whether an inventor's right to terminate an agreement by which he conveyed helicopter patents to an aircraft manufacturer was a "substantial right to a patent" within the meaning of § 117(q) of the Internal Revenue Code of 1939 which permits an inventor to treat as capital gains the royalties received in return for the transfer of all substantial rights to patents.1

Taxpayers...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases