203 F2d 954 Gregg v. Commissioner of Internal Revenue

203 F.2d 954

53-1 USTC P 9339, 97 U.S.P.Q. 192

Lynne GREGG, Petitioner,

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent.

Jon GREGG, Petitioner

v.

COMMISSIONER OF INTERNAL REVENUE, Respondent.

Nos. 10873, 10874.

United States Court of Appeals

Third Circuit.

Argued April 6, 1953.

Decided April 17, 1953.

Thomas Erskine, Philadelphia, Pa. (James F. McMullan, Clark, Ladner, Fortenbaugh & Young, Philadelphia, Pa., on the brief) for appellants.

Melva M. Graney, Washington, D.C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Sp. Asst. to the Atty. Gen., on the brief), for respondent.

Before GOODRICH, McLAUGHLIN and HASTIE, Circuit Judges.

PER CURIAM.

view counter
1

These appeals from decisions of the Tax Court raise the question whether an agreement between the taxpayers and a manufacturing company constituted a license to use a patent or a sale thereof. The Tax Court, upon examination of the agreement, concluded that the transaction was a license. We agree and for the reasons stated in that court's opinion in 18 T.C. 291.

2

The decisions will be affirmed.