Cheryl J. Miller v. CIR
The Tax Court concluded that unallocated family support payments deducted on Miller's former husband's federal tax return as sec. 215 alimony payments were not taxable alimony. Miller did not include the payments she received as sec. 71 alimony. The Tax ...
Unallocated Family Support Payments Are Not Deductible Alimony
The Tax Court concluded that unallocated family support payments deducted on Miller's former husband's federal tax return as sec. 215 alimony payments were not taxable alimony.
Compaq Computer Corporation v. Commissioner of Internal Revenue
The issue addressed in this opinion is whether income relating to printed circuit assemblies (PCA's) should be reallocated under section 482 to petitioner from its Singapore subsidiary for its 1991 and 1992 fiscal years. (A separate opinion will addre ...
Linda J. Baxter v. CIR
The Tax Court concluded that house payments made pursuant to a divorce instrument which a former husband deducted from his income as IRC sec. 215 alimony payments but the former wife did not include in her taxable income as IRC sec. 71 payments were alimo ...
House Payments Are Deductible Alimony
The Tax Court concluded that house payments made pursuant to a divorce instrument, which a former husband deducted from his income as IRC sec. 215 alimony payments but the former wife did not include in her taxable income as IRC sec. 71 payments, were alimony.
Dexsil Corporation (Dexsil II) v. CIR
The U.S. Court of Appeals for the Second Circuit reversed and remanded the Tax Court's decision reducing Dexsil's sec. 162 deduction because it found the CEO's compensation unreasonable. The Second Circuit ruled that the five step Rapco analysis applied ...
Hypothetical Investor Test Used When Determining Reasonable Compensation
The U.S. Court of Appeals for the 2nd Circuit reversed and remanded the Tax Court's decision reducing Dexsil's sec. 162 deduction because it found the CEO's compensation unreasonable.
Capital Gains Tax Determined on Value of Property Before Distribution to Transitional Limited Partnership
Pope & Talbot Inc. distributed certain real property to Pope Resources, a newly formed Delaware limited partnership.
Dexsil Corporation (Dexsil III) v. CIR
The Tax Court affirmed its earlier decision denying Dexsil an IRC sec. 162 deduction in excess of reasonable compensation. It rejected Dexsil's evidence of the annual rate of return for NYSE companies. The court found that the NYSE evidence did not indic ...
The Hypothetical Investor Test Is Not Limited to a Rate of Return Analysis
The Tax Court affirmed its earlier decision denying Dexsil an IRC sec. 162 deduction in excess of reasonable compensation.
Weight Given to Previous Compensation Levels When Determining Reasonable Compensation
The U.S. Court of Appeals for the 6th Circuit reversed the U.S. Tax Court and permitted Alpha Medical to deduct the full $4.4 million salary it paid its founder and CEO under IRC sec. 162.
Alpha Medical, Inc. (Alpha Medical II) v. CIR
The U.S. Court of Appeals for the Sixth Circuit reversed the U.S. Tax Court and permitted Alpha Medical to deduct the full $4.4 million salary it paid its Founder and CEO under IRC sec. 162. The Sixth Circuit reviewed the lower court's analysis of the com ...
Curtis L. Anderson v. CIR
The Tax Court concluded that payments a former husband made to his former spouse that were in the nature of spousal maintenance were not alimony payments for tax purposes. It found that because the payments were not made pursuant to divorce or separation ...
Payments Not Made Under Divorce Agreement Are Not Taxable Alimony
The Tax Court concluded that payments a former husband made to his former spouse that were in the nature of spousal maintenance were not alimony payments for tax purposes.
Pope & Talbot, Inc. v. Commissioner of Internal Revenue
At issue is the fair market value of the property the plaintiff distribtued to a limited partnership.
Aggregate Value of Publicly Traded Partnership Units Is Not Equal to the Value of the Underlying Assets
The 9th Circuit affirmed the Tax Court's decision to calculate the tax due under IRC sec. 311 based on the fair market value of property the corporation transferred to a limited partnership.
DHL Corporation and Subsidiaries v. Commissioner of Internal Revenue
At issue are deficiencies in income tax for petitioner.
DHL Corporation and Subsidiaries v. Commissioner of Internal Revenue
Income tax deficiencies and penalties assessed against petitioner were challenged.
Court Enumerates Five-Factor Reasonable Compensation Test; Experts Offer Little Evidence; Testimony Accorded Little Weight
The main issue at hand in this case is the amount that Labelgraphics is entitled to deduct under Section 162 as reasonable compensation to its president, Lon Martin.
Covenant Not to Compete Key to Intangible Asset Value
The principal issue underlying these consolidated cases is the fair market value of the corporation's assets on the date of distribution.
Intangible Asset Valuation Evidence Inadequate
Lorvic Holdings Inc. was engaged in the development, design, manufacturing, marketing, distribution, and sale of a variety of healthcare products for the professional dental market.
Relief-From-Royalty Method Inappropriate for Sale of Intangible Assets
In January 1985, Carnation Co. became a consolidated subsidiary of Nestle Holdings Inc.
Alexandria M. Medlin v. CIR
The Tax Court concluded that a former spouse's automotive and healthcare expenses, which were paid by the former husband's automobile dealership, were taxable alimony under IRC sec. 71 since they were paid pursuant to a divorce instrument and made on beha ...
Automobile Payments Are Taxable Alimony
The Tax Court concluded that a former spouse's automotive and healthcare expenses, which the former husband's automobile dealership paid, were taxable alimony under IRC sec. 71 since they were paid pursuant to a divorce instrument.
Labelgraphics, Inc. v. Commissioner (I)
The main issue in this case is the amount that Labelgraphics is entitled to deduct under Section 162 as reasonable compensation to its president.