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Carney v. Carney

Reviewing court says in valuing owner spouse’s auto transport business and performing equitable distribution analysis, trial court erred when it refused to consider tax effects of potential sale of business before assigning asset to owner; case remanded.

Tax Effects Are Relevant to Equitable Distribution Analysis

Reviewing court says in valuing owner spouse’s auto transport business and performing equitable distribution analysis, trial court erred when it refused to consider tax effects of potential sale of business before assigning asset to owner; case remanded.

CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

Amazon.com, Inc. v. Commissioner (I)

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

Compromised Asset Appraisals Undo Like-Kind Tax Plan

Tax Court says taxpayer’s transactions fail to meet Section 1031 requirements for income tax deferral; legal advisor’s ongoing interference with appraisal process compromised asset appraisals undergirding transactions to the point they became “useless.”

Key Tax Ruling From Ohio Supreme Court Concerning Pass-Through Entity

Ohio Supreme Court says tax provision imposing state income tax on capital gain realized by nonresident investor in pass-through entity violates taxpayer’s due process rights barring showing taxpayer’s activities are “unitary with” those of the business.

Compromised Asset Appraisals Undo Like-Kind Tax Plan

Tax Court says taxpayer’s transactions fail to meet Section 1031 requirements for income tax deferral; legal advisor’s ongoing interference with appraisal process compromised asset appraisals undergirding transactions to the point they became “useless.”

Exelon Corp. v. Commissioner

Tax Court says taxpayer’s transactions fail to meet Section 1031 requirements for income tax deferral; legal advisor’s ongoing interference with appraisal process compromised asset appraisals undergirding transactions to the point they became “useless.”

Key Tax Ruling From Ohio Supreme Court Concerning Pass-Through Entity

Ohio Supreme Court says tax provision imposing state income tax on capital gain realized by nonresident investor in pass-through entity violates taxpayer’s due process rights barring showing taxpayer’s activities are “unitary with” those of the business.

Devoid of Goodwill, Corporation Escapes Income Tax Liability

Tax Court says taxpayer’s company owned no corporate goodwill and had no right to taxpayer’s personal goodwill and, therefore, was not liable under IRC Sect. 311(b)(1); the taxpayer, in turn, was not liable for gifting corporate goodwill to his sons.

Absent Appearance by Appraiser, Valuation Report Is Hearsay

In an income tax case where the IRS challenges the calculation of net unrealized built-in gain that has been based on a contemporaneous valuation of the assets subject to built-in gain tax, the valuation report by itself constitutes inadmissible hearsay where the preparing appraiser is not available for cross-examination.

Van Der AA Investments, Inc. v. Commissioner

In an income tax case where the IRS challenges the calculation of net unrealized built-in gain that has been based on a contemporaneous valuation of the assets subject to built-in gain tax, the valuation report by itself constitutes inadmissible hearsay w ...

Valuation of Acquiree’s Customer Accounts Using Acquirer’s Data Upheld

Charles Schwab amortized the customer accounts that it had acquired through a merger. The Commissioner challenged the amortization and this suit followed.

Proper Valuation Evidence Critical for Intangible Asset Loss Deduction

The valuation issue in this case was whether the specific and independent fair market value of 376 terminated health insurance group contracts had been sufficiently established to claim a loss deduction and evade the mass asset rule.

Capital Blue Cross v. Commissioner

At issue was the value of intangible assets for loss deductions.

The Charles Schwab Corporation v. Commissioner

Petitoner demonstrates it could determine the useful life of customer accounts it acquired after purchasing "Rose & Co." and therefore amortize them.

Grossly Inflated Sale Price, Nonrecourse Financing, and Negative Cash Flows Add Up to a Tax Shelter Not Engaged in for Profit

The issue was whether taxpayer was entitled to an $18,956 deduction related to his limited partnership interest for 1981 and whether he was liable for a valuation overstatement.

Court Accepts Analogy of Outside Board Chair for Reasonable Compensation Case

The issue in this case was whether the company could deduct amounts paid to an officer-shareholder as reasonable compensation during the tax years at issue.

9th Circuit Affirms Tax Court; Noncompete Must Be Amortized Over 15 Years, Not Life of Agreement

Redemption was an “acquisition” within the meaning of IRC section 197 because Frontier regained possession and control over 75% of its stock.

Redemptions of ESOP Shares Were Deductible Dividends

The question of whether the distributions to plan participants are deductible dividends depends on who owned the convertible preferred stock when the redemptions took place.

Walford v. Commissioner

The overvaluation of an "emergency management system" resulted in the Commissioner disallowing a deduction made on the basis of the value of that asset. Subsequent sale showed act ...

Subsidiaries' Licensing of IP Rights to Parents Created Sufficient Taxing Nexus

These consolidated cases concerned state income taxes of two corporations that did no business in Maryland but were subsidiaries of parents that did do business there.

E.J. Harrison and Sons, Inc. v. Commissioner

Issue is whether compensation paid to taxpayer's officer was reasonable compensation that was therefore deductible.

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.

Comptroller v. SYL, Inc.

Issue is whether there is a sufficient nexus between the State of Maryland and each subsidiary corporation to impose Maryland income tax.

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