More Cases … Income Tax: International Multifoods

Business Valuation UpdateVol. 3 No. 3
Legal and Court Case Update
March 1997

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5461 Retail Bakeries
311811 Retail Bakeries
federal taxation
International Multifoods v. Commissioner
108 T.C. 25, 108 T.C. No. 3, 1997 U.S. Tax Ct. LEXIS 3
January 29, 1997
US
Federal Court
United States Tax Court
Robert F. Reilly (for petitioner)
Ruwe

Summary

At issue is the whether the amounts allocated to goodwill and a covenant not to compete with this business sale constitute U.S. source income or foreign source income for the purpose of allowing a foreign tax credit carryback.

See Also

International Multifoods v. Commissioner

Full Text of Court Cases
January 29, 1997

At issue is the whether the amounts allocated to goodwill and a covenant not to compete with this business sale constitute U.S. source income or foreign source income for the purpose of allowing a foreign tax credit carryback.