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.
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