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U.S. MINERAL PRODUCTS CO. v. COMMISSIONER

Docket No. 4733-66.

52 T.C. 177 (1969)

UNITED STATES MINERAL PRODUCTS COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 5, 1969.

Attorney(s) appearing for the Case

Arnold J. Zurcher, Jr., David W. Feeney, and John M. Fedders, for the petitioner.

Julius M. Jacobs and Denis M. Neill, for the respondent.

DAWSON, Judge:

Respondent determined deficiencies in petitioner's Federal income tax for its taxable years ended March 27, 1960, and March 26, 1961, in the respective amounts of $12,575.32 and $17,952.92.

The issue for decision is whether amounts received by petitioner during the years in issue from its Canadian subsidiary as payments for the transfer by it to the Canadian subsidiary of certain rights relating to patents, trademarks, and know-how are...

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