T.C. Memo. 2002-107 UNITED STATES TAX COURT IMPACT RESEARCH CORPORATION, JOAN C. BENZ, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent RESEARCH IMPACT CORPORATION, JOAN C. BENZ, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 14872-98, 14873-98.1 Filed April 29, 2002. S-1 and S-2 were S corporations formed to finance the research and development activities of A, a nonpublicly traded C corporation engaged in the business of developing educational videodiscs. In a series of written agreements between S-1, S-2, and A, (1) S-1 and S-2 acquired proprietary rights in the results of the research which A was to perform on their behalf, (2) A was obligated to pay royalties to S-1 and S-2, and (3) A was given the option to 1The petition in each docket was filed by Frank Colenda, the tax matters person of each of the named corporations. After trial and the filing of all briefs, the Court was notified that Frank Colenda died. After appropriate representations, we granted petitioners’ counsel’s motion in both dockets to (1) substitute Joan C. Benz for Frank Colenda as tax matters person and (2) change captions to reflect this substitution.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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