Sale of Nonprofit Facility Results in Inurement to Buyers; Court Refuses to Receive IRS Expert's Report in Evidence
According to the court, "The primary issue for decision is whether petitioner's tax-exempt status should be revoked."
Custom Chrome, Inc. and Subsidiaries v. CIR
The Tax Court determined that a non-compete agreement executed in connection with a leveraged buyout of a motorcycle company by a M&A firm had economic reality since the firm would not have completed the transaction without the non-compete, and because th ...
Original Issue Discount and Noncompete Agreement Considered in Connection With an LBO
The Tax Court determined that a noncompete agreement executed in connection with a leveraged buyout of a motorcycle company by a M&A firm had economic reality since the firm would not have completed the transaction without the noncompete.
Payne v. Commissioner
Commissioner contends that the value of the stock, $500,000, Payne received and claimed on his tax returns were significantly undervalued.
Value Hinges on Reasonable Compensation to an Indispensable Executive
After concessions, the issue for consideration is the amount that Exacto Spring Corp. is entitled to deduct as reasonable compensation to an indispensable executive.
Lorvic Holdings, Inc. v. CIR
The Tax Court valued a non-compete and secrecy agreement executed in connection with the sale of a dental products company. Both parties provided the court with experts, who valued the business with and without the agreements in place using the discounte ...
Nestle Holdings, Inc. v. Commissioner
Issue is the capital gains realized by Nestle Holdings, Inc. when it acquired the intangible assets of Carnation Company.
Nestlé Holdings, Inc. V. Commissioner of Internal Revenue
Nestlé Holdings, Inc. appeals from a United States Tax Court decision (Mary Ann Cohen, Chief Judge ). We hold that appellant realized a capital gain when it sold intangible rights to its shareholder for an amount exceeding the property's fair market value ...
William Norwalk, et al. v. CIR
The Tax Court concluded that without non-compete agreements executed in favor of the company, the goodwill in a professional accounting practice was the property of the accountant. Therefore, it rejected the IRS's position that goodwill was distributed t ...
Anclote Psychiatric Center v. Commissioner (II)
The primary issue is whether petitioner's tax-exempt status should be revoked, and whether the sale of its hospital in May 1983 was for less than fair market value.
Thomas H. Nelson and Donna J. Zullo Nelson v. CIR
The Tax Court concluded that payments meeting the definition of taxable alimony in IRC sec. 71 are taxable alimony regardless of the Ohio courts' characterization of the payments as part support and part property settlement.
Payments Meeting Sec. 71 Definition Are Taxable Alimony
The Tax Court concluded that payments meeting the definition of taxable alimony in IRC sec. 71 are taxable alimony regardless of the Ohio courts' characterization of the payments as part support and part property settlement.
Stephen D. Podd v. Commissioner of Internal Revenue
The following cases are consolidated herewith for purposes of trial, briefing, and opinion: Victor I. Podd, docket No. 20226-93; Victor T. Podd, docket No. 20227-93; Powertex, Inc., docket No. 20228-93; Powertex, Inc., docket No. 20229-93; Powertex, I ...
Payne v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Exacto Spring Corporation v. Commissioner (I)
Isue for consideration is the amount that Exacto Spring Corporation is entitled to deduct as reasonable compensation to an indispensable executive.
LaCrosse Footwear v. United States
Issue was whether the base-year cost of items entering the inventory in the base year should be set at bargain cost or fair market value (FMV).
Martin Ice Cream Company v. CIR
The Tax Court valued a 51percent interest in an ice cream distributor. The shareholders disagreed and split the company. The majority shareholder transferred his shares in exchange for a subsidiary which held the super premium ice cream distribution bus ...
Sale of Subsidiary After Split-Off Does Not Establish Value of That Subsidiary
The Tax Court valued a 51% interest in an ice cream distributor.
Larry Wade Human v. CIR
The Tax Court concluded that a payment of lump sum alimony was not taxable alimony for federal tax purposes. Since the divorce instrument was silent regarding a death contingency, the court looked to Georgia law and found that a lump sum alimony award, u ...
Lump-Sum Alimony Is Not Taxable Alimony
The Tax Court concluded that a payment of lump-sum alimony was not taxable alimony for federal tax purposes.
Dewey and Carlena K. Hammond v. CIR
The Tax Court concluded that payments meeting the requirements of IRC sec. 71 for taxable alimony were not taxable alimony because the payments ceased upon a contingency related to a child, and thus fell into the IRC sec. 71 (c)(2) exception.
Support Payments Are Not Taxable Alimony When Contingent to a Child
The Tax Court concluded that payments meeting the requirements of IRC sec. 71 for taxable alimony were not taxable alimony because the payments ceased upon a contingency related to a child and thus fell into the IRC sec. 71 (c)(2) exception.
More Court Cases … Income Tax: Valley Medical
At issue is whether royalty payments are reasonable in amount and therefore considered to be a deductible expense incurred in carrying on a trade or business under Section 162(a)(3).
Executive’s Compensation Found Unreasonable
The Tax Court considered whether a CEO's compensation was reasonable and thus deductible to the company under IRC Sec. 162.
Alpha Medical, Inc. (Alpha Medical I) v. CIR
The Tax Court considered whether a CEO's compensation was reasonable and thus deductible to the company under IRC Sec. 162. The Tax Court applied a multi-factor test which considered the executive's qualifications, the executive's past compensation, the ...