Dodson v. Commissioner
United States Tax Court
Finance company sold all of its assets under written agreements which provided that $ 37,000 of the total purchase price of $ 187,200 was allocated to covenants not to compete.
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Finance company sold all of its assets under written agreements which provided that $ 37,000 of the total purchase price of $ 187,200 was allocated to covenants not to compete. Seller contends that said agreements were a nullity because its corporate resolution was in fact a prior written contract of sale with no covenant; because said resolution did not authorize sales to the buyers who in fact acquired; and (alternatively) because the written agreements were procured by fraud so that covenants were not in fact sold. Seller concedes that its reserve for bad debts is includable in income in…
1Opinion of the Court
John T. Dodson, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Dodson v. Commissioner
Docket Nos. 4715-66, 4716-66, 4717-66, 4718-66, 4719-66
United States Tax Court
52 T.C. 544; 1969 U.S. Tax Ct. LEXIS 104;
June 25, 1969, Filed
Decisions will be entered under Rule 50.
Finance company sold all of its assets under written agreements which provided that $ 37,000 of the total purchase price of $ 187,200 was allocated to covenants not to compete. Seller contends that said agreements were a nullity because its corporate resolution was in fact a prior written contract of sale with…
2Cases cited17 opinions
- Danielson v. CommissionerUnited States Tax Court · 1965
- Schmitz v. CommissionerUnited States Tax Court · 1968
- Horner v. AhernSupreme Court of Virginia · 1967
- Emmette L. Barran and Martha Barran v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- General Insurance Agency, Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Helen R. ThrockmortonCourt of Appeals for the Fourth Circuit · 1968
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