Plaintiffs were partners in a wholesale produce business which was well established and had a large goodwill value in the area. Plaintiffs sold the whole business, including goodwill, to another produce dealer, with a specific portion of the sale price being allocated to the sale of the goodwill. Included in the sale contract was an agreement by the sellers not to compete with the purchaser for a certain number of years, but it was understood by the parties that none of the sale price was given in consideration of this agreement. Plaintiffs returned the amount received from the sale of goodwill as gain from the sale of a capital asset. The Commissioner of Internal Revenue assessed a deficiency on the theory that this amount should be consid...
The owners of the entire capital stock of a newspaper business received an offer of $1,000,000 for t...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
Petitioners, from 1937 to 1940, received distributions from the liquidation of a corporation of whic...
Petitioner sold a farm owned over six months upon which was a growing but unmatured wheat crop. When...
In 1915 petitioner and husband purchased property by the entirety for $13,000. Petitioner contribute...
Taxpayer was engaged in the business of raising and breeding beef cattle. Each year he would add to ...
The United States Tax Court has held that section 741 of the Internal Revenue Code controls the char...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
When a business that is a C corporation is sold, is it possible that related intangibles, including ...
Executors were directed to sell the testator\u27s residuary estate. Out of one-fifth of the proceeds...
Petitioner owned two parcels of real estate across the street from each other which were used as one...
Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the ope...
Plaintiff sold all the assets used in its business, in the middle of a fiscal year, at a price in ex...
The owners of the entire capital stock of a newspaper business received an offer of $1,000,000 for t...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
Petitioners, from 1937 to 1940, received distributions from the liquidation of a corporation of whic...
Petitioner sold a farm owned over six months upon which was a growing but unmatured wheat crop. When...
In 1915 petitioner and husband purchased property by the entirety for $13,000. Petitioner contribute...
Taxpayer was engaged in the business of raising and breeding beef cattle. Each year he would add to ...
The United States Tax Court has held that section 741 of the Internal Revenue Code controls the char...
The stockholders of a closely held electric utility corporation offered to sell all the corporate st...
When a business that is a C corporation is sold, is it possible that related intangibles, including ...
Executors were directed to sell the testator\u27s residuary estate. Out of one-fifth of the proceeds...
Petitioner owned two parcels of real estate across the street from each other which were used as one...
Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the ope...
Plaintiff sold all the assets used in its business, in the middle of a fiscal year, at a price in ex...
The owners of the entire capital stock of a newspaper business received an offer of $1,000,000 for t...
In 1932 the taxpayer sold to the X corporation, which he wholly owned and controlled, certain shares...
The recent Supreme Court decision in Le Tulle v. Scofield, disapproving the views of four out of fiv...