Raytheon Production Corporation v. Commissioner

144 F.2d 110, cert denied 323 U.S. 779 (1944)

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Nature of the Case

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Facts

Raytheon filed a suit and alleged that the illegal conduct of R.C.A. completely destroyed the profitable interstate and foreign commerce of its tube business. Raytheon alleged that by 1928, its business with a value in excess of three million dollars was now worthless. The allegations and evidence of the amount of profits was used to establish goodwill and a method on which to recover a return of capital. The suit was ended in a compromise settlement. The IRS got involved and said that this settlement was taxable as income. Raytheon disagreed and appealed that decision.