117 T.C. No. 4
UNITED STATES TAX COURT
ILLINOIS TOOL WORKS, INC. & SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16022-99. Filed July 31, 2001.
P acquired the assets of D and assumed certain
liabilities, including the contingent liability for a
patent infringement claim. P was subsequently held
liable for damages, interest, and court costs.
Held: P’s payment in satisfaction of the patent
infringement liability is a cost of acquiring the
assets of D and must be capitalized in the year
incurred.
James P. Fuller, Jennifer L. Fuller, Laura K. Zeigler,
William F. Colgin, Jr., and Kenneth B. Clark, for petitioner.
Rogelio A. Villageliu, for respondent.
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