Dharma Enterprises v. Commissioner
At issue is whether the royalties paid to Dharma Mudranalaya for certain intangible assets were reasonable in amount.
Tax Court Details Noncompete Covenant
The issue in this case is whether State Supply, a distributor of beauty supply products organized as an S corporation, may amortize $2.5 million for noncompete covenants.
Kirk A. Keegan, Jr. v. CIR
The Tax Court determined that spousal support payments made prior to the entry of the separation agreement did not qualify as deductible alimony under IRC sec. 71(b)(2). The husband evidenced a letter offering to make the payments. However, the court dete ...
Payments Made Prior to Divorce Instrument Are Not Deductible Alimony
The Tax Court determined that spousal support payments made prior to the entry of the separation agreement did not qualify as deductible alimony under IRC sec. 71(b)(2).
Court Rejects Discounted Cash Flow Model in Highly Leveraged Company
At issue is the fair market value of Soft Warehouse Inc. (SWI) stock a key employee purchased on June 30, 1989.
Thompson, C. v. Commissioner (I)
The Tax Court determined whether noncompete agreements executed in connection with the sale of a beauty supply business had economic reality. The court accepted the testimony of the taxpayer's expert who valued the business using the discounted cash flow ...
Thompson, C v. Commissioner (II)
Case name: Thompson v. Commissioner Citation: 1997 Tax Ct. Memo LEXIS 341 At issue is whether State Supply may amortize $ 2.5 million, or some lesser amount, for covenants not to compete.
Colgate's Bid to Reduce Federal Taxes Fails
In a complex transaction aimed at reducing federal taxes, Colgate, Merrill Lynch, and ABN Ambro Bank formed a partnership, ACM.
Stephen A. Raymond v. CIR
The Tax Court concluded that unallocated support payments made under a separation agreement qualified as alimony payments under IRC sec. 71 and sec. 215. It concluded that while an amount of the payments went to support the parties' children, the separa ...
Linda Gibbs v. CIR
The Tax Court concluded that the interest portion of payments Gibbs received from her former husband in exchange for her interest in their convenience store business were not deductible from her income under IRC sec. 1041 - transfers incident to divorce.
Interest on Payments Received in Divorce Is Income
The Tax Court concluded that the interest portion of payments Gibbs received from her former husband in exchange for her interest in their convenience store business were not deductible from her income under IRC sec. 1041—transfers incident to divorce.
Morton v. Commissioner
At issue is fair market value of the capital stock of Soft Warehouse, Inc.
More Cases … Income Tax: International Multifoods
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.
More Cases … Income Tax: Utilicorp United
The IRS determined that Utilicorp improperly included in the depreciable cost of goodwill or going concern value.
Pope & Talbot, Inc. v. CIR
The Tax Court determined the fair market value of timberland and resort property that was distributed to a publicly traded Pope & Talbot subsidiary for IRC sec. 311 gain purposes. In reaching its valuation, the court considered the price at which the subs ...
Jeff A. Wiltzius, et al. v. CIR
The Tax Court valued a note received by the taxpayers in the distribution of their former business' assets. They had owned a topless bar. The court determined that the starting point for valuing the note was its face value, which it reduced by 25% for ris ...
Value of Promissory Note From Sale of Topless Bar Discounted 25%
The Tax Court valued a note the taxpayers received in the distribution of their former business's assets.
ACM Partnership v. Commissioner
Issues are whether subject transactions lacked economic substance, foreign partner should be treated as a lender, and allocation of taxable gain had substantial economic effect.
M.I.C. Ltd. v Commissioner
The Tax Court determined that none of the price paid for the city’s threatened condemnation of property operated as a multipurpose adult entertainment complex was attributable to goodwill or going-concern value. In so doing, the Tax Court made its own determination of the fair market value of the real estate.
Tax Court Determines That Gain on Sale of Property to the City Is All Related to the Property and Therefore Is Deferred Under IRC Sec. 1033
The Tax Court determined that none of the price paid for the city’s threatened condemnation of property operated as a multipurpose adult entertainment complex was attributable to goodwill or going-concern value. In so doing, the Tax Court made its own determination of the fair market value of the real estate.
International Multifoods v. Commissioner
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.
Court Rejects All Experts; Articulates Tax Valuation Principles
The issue is the fair market value of certain assets Pabst transferred to G. Heileman Brewing Co. during the taxable period ended March 19, 1983.
Utilicorp United v. Commissioner
At issue is whether one member of the affiliated group, Utilicorp, Inc. (UtilCo), improperly included in the depreciable basis of certain property the nondepreciable cost of goodwill or going concern value.
Jean A. Stanko (Stanko I) v. CIR
The Tax Court affirmed the IRS's valuation of a note received in the sale of a business. The business owner transferred the note to Stanko and failed to file the company's last tax return. The service held Stanko liable as a transferee for the company's t ...
IRS’ Value of Promissory Note Upheld
The Tax Court affirmed the IRS' valuation of a note received in the sale of a business.