Allocation of Stock Purchase Price to Noncompete Must Be Clear, Unambiguous

Business Valuation UpdateVol. 13 No. 2
Legal and Court Case Update
February 2007

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0174 Citrus Fruits
111310 Orange Groves
federal taxation
Becker v. Commissioner of Internal Revenue
2006 Tax Ct. Memo LEXIS 268
December 13, 2006
US
Federal Court
United States Tax Court
Andrew M. Tiktin, Ellen Wasserstrom, James P. Dawson, Jerald David August, Michael K. Green, Scott M. Dayan, Sergio Garcia-Pages, Stanley H. Eleff, William P. Ewing
none
Haines

Summary

Tax Court declines to allocate a portion of stock purchase to a noncompete when documents unambiguously allocate the entire price to the stock.

See Also

Becker v. Commissioner of Internal Revenue

Full Text of Court Cases
December 13, 2006

Tax Court declines to allocate a portion of stock purchase to a non-compete, when documents unambiguously allocate the entire price to the stock.