United States Board of Tax Appeals December 23, 1926, Docket No. 3170 (Buffalo Forge Co. v. Commissioner)

*951OPINION.

Littleton:

Petitioner claims (1) that the fair market price or value of the English rights of the patent on March 1, 1913, was $150,000, and that it therefore derived no taxable gain from the sale thereof in 1917; (2) that in the event the Board does not agree with it as to the March 1, 1913, value, the cost of $95,592.