Charles C. Cullen v. CIR
The Tax Court concluded that a businessman did not receive any goodwill in the liquidation and conversion of his corporation to a sole proprietorship. It reasoned that the goodwill was personal to the businessman and remained his personal property absent ...
Goodwill Belonged to Sale Owner, Not Business
The Tax Court concluded that a businessman did not receive any goodwill in the liquidation and conversion of his corporation to a sole proprietorship.
D. K. MacDonald v. CIR
The Tax Court concluded that an insurance agent did not received any goodwill in the liquidation of his insurance corporation. It found that the goodwill was the personal property of the agent absent a non-compete agreement.
No Goodwill Distributed in Liquidation
The Tax Court concluded that an insurance agent did not received any goodwill in the liquidation of his insurance corporation.
Gregory v. Helvering (Commissioner)
Held : while the plan of reorganization conformed to the terms of the statute, there was no reorganization within the intent of the statute, merely a tax avoidance purpose.