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Relief-From-Royalty Method Inappropriate for Sale of Intangible Assets

In January 1985, Carnation Co. became a consolidated subsidiary of Nestle Holdings Inc.

Nestle Holdings, Inc. v. Commissioner

Issue is the capital gains realized by Nestle Holdings, Inc. when it acquired the intangible assets of Carnation Company.

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.

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.

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