Opinion · Court of Appeals for the Third Circuit

William M. Bailey v. Commissioner of Internal Revenue

William M. Bailey v. Comm’r of Internal Revenue, 188 F.2d 360 (3d Cir. 1951)

Type: Opinion
Court: Court of Appeals for the Third Circuit
Jurisdiction: Federal
Date: 1951-05-01
Topic: general

PER CURIAM. There is ample evidence to support the findings of the Tax Court that petitioner had not made an outright' sale of his invention as he claims and that, therefore, the proceeds of the transaction are taxable to him as ordinary income. The decision of the Tax Court will be affirmed.

Citator

UpLaw has not yet analyzed William M. Bailey v. Commissioner of Internal Revenue. The absence of a flag is not a finding that it is good law.

BAILEY v. COMMISSIONER OF INTERNAL REVENUE,188 F.2d 360(3rd Cir. 1951)

William M. BAILEY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE,

Respondent.

No. 10407.

United States Court of Appeals, Third Circuit.

Argued April 17, 1951.

Decided May 1, 1951.

On Petition for Review of Decision of the Tax Court of the United States.

William Wallace Booth, Pittsburgh, Pa. (Charles L. Albright, Jr. and Reed, Smith, Shaw McClay, all of Pittsburgh, Pa., on the brief), for petitioner.

Louise Foster, Washington, D.C. (Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, A.F. Prescott, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before McLAUGHLIN, STALEY and HASTIE, Circuit Judges.

PER CURIAM.

There is ample evidence to support the findings of the Tax Court that petitioner had not made an outright sale of his invention as he claims and that, therefore, the proceeds of the transaction are taxable to him as ordinary income. The decision of the Tax Court will be affirmed.