Legal Opinion

International Multifoods Corporation and Affiliated Companies v. Commissioner

United States Tax Court

Decided January 29, 1997No. 11643-92Unknown

1Opinion of the Court

108 T.C. No. 3

UNITED STATES TAX COURT INTERNATIONAL MULTIFOODS CORPORATION AND AFFILIATED COMPANIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11643-92. Filed January 29, 1997. P was in the business of franchising the right to operate Mister Donut shops in the United States and abroad. On Jan. 31, 1989, P sold its Asian and Pacific Mister Donut business operations for $2,050,000. Pursuant to the agreement, P transferred its franchise agreements, trademarks, Mister Donut System, and goodwill for each of the Asian and Pacific countries in which P had existing…

2Cases cited29 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  3. National Labor Relations Board v. Amax Coal Co.Supreme Court of the United States · 1981
  4. Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
  5. Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993

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