Legal Opinion
S. S. Ballin Agency, Inc. v. Commissioner
Court of Appeals for the Third Circuit
Decided July 8, 1971No. Tax Court Docket No. 6225-66; Tax Court Docket No. 6226-66; Tax Court Docket No. 932-67; Nos. 19035-19037PublishedCited by 7 opinions
1Opinion of the Court
OPINION OF THE COURT
ALDISERT, Circuit Judge.
These appeals from decisions of the Tax Court present the question whether appellant met its burden of establishing that certain acquired intangible assets qualified for amortization for a limited period of time and that the length of this period was estimable with reasonable accuracy. The Tax Court held that appellant1 failed to meet its burden. We affirm.
By written contract of sale S. S. Ballin Agency, Inc., purchased, for $156,-000, a business known as United Health Agency, a single proprietorship owned by Joseph Delman. The agency represented…
2Cases cited10 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Thrifticheck Service Corp. v. CommissionerUnited States Tax Court · 1960
- Clifford F. Mack and Helen L. Mack v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Union Bankers Ins. Co. v. CommissionerUnited States Tax Court · 1975
- Tomlinson v. CommissionerUnited States Tax Court · 1972
- S.S. Ballin Agency, Inc., in No. 19035 v. Commissioner of Internal Revenue (Tax Court Docket No. 6225-66). S.S. Ballin Agency, Inc., and Subsidiary Company, in No. 19036 v. Commissioner of Internal Revenue (Tax Court Docket No. 6226-66). Joseph Delman and Jeanette Delman v. Commissioner of Internal Revenue, in No. 19037 (Tax Court Docket No. 932-67)Court of Appeals for the Third Circuit · 1971
- Simon v. Comm'rUnited States Tax Court · 1994
- Simon v. Comm'rUnited States Tax Court · 1994
2 more not listed; retrieve them via the Exa API.