Appeal of the Nachmann Co.

Board of Tax Appeals

Appeal of the Nachmann Co.

4 B.T.A. 1271

CourtUnited States Board of Tax Appeals

DecidedSeptember 30, 1926

DocketDocket No. 4880

StatusPublished

Cited by1 cases

This text of 4 B.T.A. 1271 (Appeal of the Nachmann Co.) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of the Nachmann Co., 4 B.T.A. 1271 (bta 1926).

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Opinion

[1274]*1274OPINION.

Littleton

: The patent license was acquired by Nachmann without cost. He expended in excess of $3,000 in developing the articles and subsequently transferred the license to the petitioner for $3,000 par value stock. The license may have had a cash value in August, 1915, but the evidence before us does not establish what such value was. The fact that Nachmann expended $3,000 in developing the patented article does not warrant a conclusion that the license had an actual cash value equal to that amount, nor do the royalties paid, or the resolution of the directors, standing alone, prove actual value.

Judgment for the Commissioner.

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[1274]*1274OPINION.

Littleton

: The patent license was acquired by Nachmann without cost. He expended in excess of $3,000 in developing the articles and subsequently transferred the license to the petitioner for $3,000 par value stock. The license may have had a cash value in August, 1915, but the evidence before us does not establish what such value was. The fact that Nachmann expended $3,000 in developing the patented article does not warrant a conclusion that the license had an actual cash value equal to that amount, nor do the royalties paid, or the resolution of the directors, standing alone, prove actual value.

Judgment for the Commissioner.

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4 B.T.A. 1271, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-the-nachmann-co-bta-1926.

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