United States Ninth Circuit

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Cooper v. Commissioner of Internal Revenue, 15-70863

Affirming the tax court's decision at trail on petition for redetermination of federal income tax deficiencies in which taxpayers sought capital gains treatment of patent-generated royalties because the tax court permissibly concluded that the patent owner did not transfer 'all substantial rights' to the patents to another, as required to avail oneself of this regime, because he continued to direct those holding the patent, they did not exercise independent judgment, and returned the patents when requested for no consideration.

Appellate Information

  • Decided
  • Published 2017/12/15




  • United States Ninth Circuit


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