7th Circuit Rejects Tax Court's Reasonable Compensation Test
The issue in this corporate income tax matter was whether the petitioner's deduction for the salary of its chief executive and principal owner was excessive, as asserted by the IRS.
7th Circuit Affirms Independent Investor Test When Determining Reasonable Compensation
The 7th Circuit reversed the U.S. Tax Court and determined that the independent investor test was the appropriate test for determining whether an executive's compensation was reasonable and, thus, deductible to the corporation under IRC sec. 162.
7th Circuit Affirms Independent Investor Test When Determining Reasonable Compensation
The 7th Circuit reversed the U.S. Tax Court and determined that the independent investor test was the appropriate test for determining whether an executive's compensation was reasonable and, thus, deductible to the corporation under IRC sec. 162.
Who can touch personal intangibles?
"Separating Entity From Personal Intangible Assets," Pratt, Shannon P., Valuation Strategies , May/June 1999, pp. 4-9. If valuing intangible assets is a difficult undertaking, determining the own ...
Court Enumerates Five-Factor Reasonable Compensation Test; Experts Offer Little Evidence; Testimony Accorded Little Weight
The main issue at hand in this case is the amount that Labelgraphics is entitled to deduct under Section 162 as reasonable compensation to its president, Lon Martin.
Relief-From-Royalty Method Inappropriate for Sale of Intangible Assets
In January 1985, Carnation Co. became a consolidated subsidiary of Nestle Holdings Inc.
Labelgraphics, Inc. v. Commissioner (I)
The main issue in this case is the amount that Labelgraphics is entitled to deduct under Section 162 as reasonable compensation to its president.
Value Hinges on Reasonable Compensation to an Indispensable Executive
After concessions, the issue for consideration is the amount that Exacto Spring Corp. is entitled to deduct as reasonable compensation to an indispensable executive.
Nestle Holdings, Inc. v. Commissioner
Issue is the capital gains realized by Nestle Holdings, Inc. when it acquired the intangible assets of Carnation Company.
Exacto Spring Corporation v. Commissioner (I)
Isue for consideration is the amount that Exacto Spring Corporation is entitled to deduct as reasonable compensation to an indispensable executive.
LaCrosse Footwear v. United States
Issue was whether the base-year cost of items entering the inventory in the base year should be set at bargain cost or fair market value (FMV).
More Court Cases … Income Tax: Valley Medical
At issue is whether royalty payments are reasonable in amount and therefore considered to be a deductible expense incurred in carrying on a trade or business under Section 162(a)(3).
Dharma Enterprises v. Commissioner
At issue is whether the royalties paid to Dharma Mudranalaya for certain intangible assets were reasonable in amount.
Court Rejects Discounted Cash Flow Model in Highly Leveraged Company
At issue is the fair market value of Soft Warehouse Inc. (SWI) stock a key employee purchased on June 30, 1989.
Colgate's Bid to Reduce Federal Taxes Fails
In a complex transaction aimed at reducing federal taxes, Colgate, Merrill Lynch, and ABN Ambro Bank formed a partnership, ACM.
Morton v. Commissioner
At issue is fair market value of the capital stock of Soft Warehouse, Inc.
ACM Partnership v. Commissioner
Issues are whether subject transactions lacked economic substance, foreign partner should be treated as a lender, and allocation of taxable gain had substantial economic effect.
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.
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.
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.
Cluck v. Commissioner of Internal Revenue
At issue is the valuation and interest in a 149.67-acre tract of land.
Krapf v. United States
Issue was the value of stock claimed as a charitable donation.
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).