Pabst Brewing v. Commissioner
At issue is the fair market value of certain assets that petitioner transferred to G. Heileman Brewing Co. during the taxable period ended March 19, 1983.
Effective Date of Critical to Valuation of Stock
This case involves a claim by the Commissioner that taxpayer is liable for income tax on the difference between the price paid for stock and its fair market value under § 83(a) of the Internal Revenue Code.
Leonard Pipeline Contractors, Ltd v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective ...
Theophilos v. Commissioner
Issue was whether the property received by the taxpayer was stock aquired in a closely held company or the contract to acquire the stock at a later time.
Theophilos v. Commissioner
At issue in this case was whether the taxpayer acquired a beneficial interest in the closely held corporation of his former employer and whether full value was paid for the 40% minority interest in nonvoting common stock.
Tax Court Denies Amortization of Lion's Share of Employment Agreement and Noncompete Payments
The Totem Lake dealerships of Kirkland, Wash., while under the ownership of Mr. Wright, experienced a great deal of negative publicity which resulted in sustained financial losses for 1986 and 1987.
Larick A. Hill v. CIR
The Tax Court concluded that payments made to a former spouse which concluded within six months of their child's 18th birthday were alimony rather than child support. It found that the payments met the requirements of Rule 142(a) and were alimony.
Payments Made to Ex-Spouse Were Alimony, Not Child Support
The Tax Court concluded that payments made to a former spouse, which concluded within six months of their child's 18th birthday, were alimony rather than child support.
Tax Court Cites Factors in Noncompete Valuation
The IRS disallowed a depreciation deduction for a covenant not to compete, saying it had no value.
Heritage Auto Center v. Commissioner
At issue is whether petitioner is entitled to deductions for amortization of amounts paid to William Wright for a noncompetition and consulting agreement.
Liquid Air Corporation and Subsidiaries v. CIR
The Tax Court permitted a blockage discount to be included in the basis of assets (calculated under IRC sec. 1012) purchased from another corporation whose purchase price was negotiated at arms'-length. The decision listed the factors consider in permitti ...
30% Blockage Discount Used
The Tax Court permitted a blockage discount to be included in the basis of assets (calculated under IRC sec. 1012) purchased from another corporation whose purchase price was negotiated at arm's length.
Anclote Psychiatric Center, Inc. v. Commissioner (I)
One issue is whether Petitioner is entitled to summary judgment on the issue of whether certain payments are deductible as ordinary and necessary business expenses.
Court Takes Position on Trademark and Unpatented Technology Values
The issues in this case pertain to the acquisition of Carnation Co. by Nestle Holdings Inc.
Beaver Bolt v. Commissioner
At issue is whether petitioner may amortize $ 383,400, or some other amount, for the ex-vice president of Beaver Bolt's covenant not to compete.
Cluck v. Commissioner of Internal Revenue
At issue is the valuation and interest in a 149.67-acre tract of land.
Nestle Holdings v. Commissioner
At issue is the fair market value of Carnation's inventory, trademarks and trade names, unpatented technology, and goodwill and going concern for federal income tax purposes.
Tax Court Provides List of Factors to Consider in Determining the Appropriate Amount of Owners’ Compensation
The Tax Court considered a list of 14 factors in determining whether compensation to a business owner was reasonable and thus deductible under IRC sec. 162.
Mad Auto Wrecking, Inc. v. CIR
The Tax Court considered a list of fourteen factors in determining whether compensation to a business owner was reasonable and thus deductible under IRC sec. 162. The factors included employee compensation, scope of employee's work, comparison to salaries ...
Sundstrand Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue
During 1977 and 1978, petitioner and its subsidiaries manufactured and sold numerous products, including the constant speed drive (CSD), an extremely complex avionic device used to drive an airplane engine's generator at a constant speed regardless of ...
Estate of Winkler v. Commissioner
Tax Court provides guidance on report writing to avoid “random walk approach” and finds respondent’s expert failed to detail thought processes underlying valuation conclusions in appraisal report.
Las Vegas Dodge v. United States
Issue was the value of stock contributed to a trust taken as income tax deductions.
Elliotts, Inc. v. Commissioner
Issue is whether part of the compensation paid Taxpayer's chief executive and sole shareholder constituted a dividend distribution and thus was not deductible under section 162(a)(1).
Buffalo Tool & Manufacturing v. Commissioner of Internal Revenue
At issue is the value of 16 n1 machines and a group of 1,101 fully depreciated items sold by Buffalo Tool.
Golsen v. Commissioner
Tax Court says "better judicial administration" requires it to follow a decision that is squarely on point from the Court of Appeals for the same circuit within which the present case arises.