Issue is whether company's redemption of 75% of its stock was an “acquisition” within the meaning of IRC section 197, and whether the covenant not to compete needed to be amortized.
Frontier Chevrolet Co. v. Commissioner
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9th Circuit Affirms Tax Court; Noncompete Must Be Amortized Over 15 Years, Not Life of Agreement
Redemption was an “acquisition” within the meaning of IRC section 197 because Frontier regained possession and control over 75% of its stock.