Entire Settlement Payment Is Purchase Price
One of the issues for the Tax Court was whether $4,856,922 of a $19,886,922 settlement made by Indeck Energy Services, Inc. to Michael P. Polsky was interest deductible by Indeck and recognizable as ordinary income to Polsky or whether it was part of the purchase price for shares of Indeck stock held by Polsky.
Indeck Energy Services, Inc. v. Commissioner
Issues are whether part of settlement payment constitutes interest deductible by Indeck and recognizable as ordinary income by petitioners, and whether penalties apply.
More Cases … Income Tax: Utilicorp United
The IRS determined that Utilicorp improperly included in the depreciable cost of goodwill or going concern value.
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.