# Automatic Sprinkler Co. v. Commissioner

> United States Board of Tax Appeals · November 12, 1926 · 5 B.T.A. 479

URL: https://www.frixlaw.com/law-library/cases/4499418

## Case

- **Full name:** APPEAL OF AUTOMATIC SPRINKLER COMPANY OF AMERICA.
- **Court:** United States Board of Tax Appeals
- **Decided:** November 12, 1926
- **Citations:** 5 B.T.A. 479; 1926 BTA LEXIS 2853
- **Precedential status:** Published
- **Opinion:** Opinion of the court by Littleton
- **Judges:** Littleton
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4499418

## Opinion text

Littleton :
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.
*480 FINDINGS OF FACT.
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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4499418. Public record. Not legal advice.