Meredith Corp. v. Commissioner
United States Tax Court
P purchased all of the assets of a consumer magazine business. As part of the purchase, P became the employer of E and acquired subscriber relationships and subscription lists. The purchase agreement made no allocation of consideration among the acquired assets. Noncompetition agreements were executed at the time of the purchase by the selling corporation and its majority shareholder.
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P purchased all of the assets of a consumer magazine business. As part of the purchase, P became the employer of E and acquired subscriber relationships and subscription lists. The purchase agreement made no allocation of consideration among the acquired assets. Noncompetition agreements were executed at the time of the purchase by the selling corporation and its majority shareholder. The noncompetition agreements unambiguously recited the amounts of consideration paid for each. 1. Held, P has failed to establish the remaining useful life and value of the employment relationship with E. 2.…
1Opinion of the Court
Meredith Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Meredith Corp. v. Commissioner
Docket Nos. 13165-91, 17091-91
United States Tax Court
102 T.C. 406; 1994 U.S. Tax Ct. LEXIS 17; 102 T.C. No. 15;
March 14, 1994, Filed
Decisions will be entered under Rule 155.
P purchased all of the assets of a consumer magazine business. As part of the purchase, P became the employer of E and acquired subscriber relationships and subscription lists. The purchase agreement made no allocation of consideration among the acquired assets. Noncompetition agreements were…
2Cases cited39 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. CartwrightSupreme Court of the United States · 1973
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
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