Concord Control, Inc. v. Commissioner
United States Tax Court
In Concord Control, Inc. v. Commissioner, T.C. Memo. 1976-301, this Court held that no goodwill was acquired by petitioner in its 1964 purchase of K-D. However, we held that part of the purchase price was attributable to nondepreciable going concern value, and we estimated such amount. The U.S.
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In Concord Control, Inc. v. Commissioner, T.C. Memo. 1976-301, this Court held that no goodwill was acquired by petitioner in its 1964 purchase of K-D. However, we held that part of the purchase price was attributable to nondepreciable going concern value, and we estimated such amount. The U.S. Court of Appeals for the Sixth Circuit affirmed our holding with respect to the existence of going-concern value, but remanded the case for us to explain our method of calculating the amount of going-concern value and why we chose that method. Held, using the capitalization of earnings method, the…
1Opinion of the Court
Concord Control, Inc., Successor in Interest to K-D Lamp Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Concord Control, Inc. v. Commissioner
Docket Nos. 3206-72, 3207-72
United States Tax Court
78 T.C. 742; 1982 U.S. Tax Ct. LEXIS 104; 78 T.C. No. 49;
April 28, 1982, Filed
Decisions will be entered under Rule 155.
In Concord Control, Inc. v. Commissioner, T.C. Memo. 1976-301, this Court held that no goodwill was acquired by petitioner in its 1964 purchase of K-D. However, we held that part of the purchase price was attributable to nondepreciable going concern value, and…
2Cases cited20 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Elmhurst Cemetery Co. of Joliet v. CommissionerSupreme Court of the United States · 1937
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
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