Legal Opinion

Lea, Inc. v. Commissioner

United States Tax Court

Decided February 22, 1978No. Docket No. 2555-72Published

Petitioner acquired the business of a competitor. The tax consequences of payments made by petitioner for that business in 1962 were decided by the Court of Claims in Davee v. United States, 195 Ct.

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Petitioner acquired the business of a competitor. The tax consequences of payments made by petitioner for that business in 1962 were decided by the Court of Claims in Davee v. United States, 195 Ct. Cl. 184, 444 F.2d 557 (1971), cert. denied 425 U.S. 912 (1976), rehearing denied 425 U.S. 1000 (1976). Respondent determined a deficiency in petitioner's Federal corporate income taxes for later years, part of which is attributed to deductions which would be disallowed under the prior decision. Held, petitioner is estopped by the prior judgment from relitigating the deductibility of payments in…

1Opinion of the Court

Lea, Incorporated, Successor by Merger to Lea Associates, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Lea, Inc. v. Commissioner

Docket No. 2555-72

United States Tax Court

69 T.C. 762; 1978 U.S. Tax Ct. LEXIS 175;

February 22, 1978, Filed

Petitioner acquired the business of a competitor. The tax consequences of payments made by petitioner for that business in 1962 were decided by the Court of Claims in Davee v. United States, 195 Ct. Cl. 184, 444 F.2d 557 (1971), cert. denied 425 U.S. 912 (1976), rehearing denied 425 U.S. 1000 (1976). Respondent determined a deficiency in…

2Cases cited17 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Kennedy v. Mendoza-MartinezSupreme Court of the United States · 1963
  3. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
  4. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  5. United States v. MoserSupreme Court of the United States · 1924

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