Appeal of Automatic Sprinkler Co. of America
Cases that cite this one
1 later published case cites this decision.
- Automatic Sprinkler Co. v. Commissioner (United States Board of Tax Appeals 1926)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
This is an appeal from the determination of deficiencies for the years 1918 and 1919 in the amounts of $32,802.85 and $7,800.80, respectively, of which amounts approximately $2,100 is in dispute.
The controversy arises from the reduction by the Commissioner from $50,000 to $25,000 of invested capital, representing alleged value of patents and license agreements.
The taxpayer is a Delaware corporation with principal office in New York City. During the taxable years it was affiliated with the Sypho-Chemical Sprinkler Corporation. On February 6, 1916, the Sypho-Chemical Sprinkler Corporation acquired for $200,000 par value of its capital stock certain patents and license agreements covering a certain automatic fire extinguishment system, which patents and license agreements had an actual cash value at the time acquired for stock of $50,000.
Judgment will he entered for the petitioner upon the issue raised on 15 days’ notice, under Rule 50.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.