Manhattan Co. of Virginia, Inc. v. Commissioner
United States Tax Court
Petitioners purchased the names and addresses of a number of home pickup-and-delivery laundry customers from another laundry company. No goodwill of any other character was purchased, and the other laundry company continued with all other facets of its business. Covenants not to compete were also purchased by petitioners in the same transaction. Held: Petitioners are not entitled to deductions in the year of purchase for the entire cost of the customer lists.
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Petitioners purchased the names and addresses of a number of home pickup-and-delivery laundry customers from another laundry company. No goodwill of any other character was purchased, and the other laundry company continued with all other facets of its business. Covenants not to compete were also purchased by petitioners in the same transaction. Held: Petitioners are not entitled to deductions in the year of purchase for the entire cost of the customer lists. The information contained on the lists constituted intangible assets, portions of which were in the nature of nondepreciable goodwill…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in income taxes of petitioner the Manhattan Co. in the amounts of $5,185.03, $2,322.48, and $1,470,67 for the taxable years 1961,1962, and 1963, respectively, and determined a deficiency in the income tax of petitioner the Manhattan Co. of Virginia, Inc., in the amount of $1,399.17 for the taxable year 1962.
The issue for decision is whether petitioners are entitled to deduct the cost of customer lists in the year of purchase, or if not, whether petitioners are entitled to deductions for amortization or depreciation of such customer lists over…
Also in this document: Concurrence.
2Cases cited15 opinions
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
- Boe v. CommissionerUnited States Tax Court · 1961
- Commissioner of Internal Revenue v. Liberty Bank & Trust Co.Court of Appeals for the Sixth Circuit · 1932
- Red Wing Malting Co. v. WillcutsCourt of Appeals for the Eighth Circuit · 1926
10 more not listed; retrieve them via the Exa API.
3Cited by78 opinions
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Finoli v. CommissionerUnited States Tax Court · 1986
- Computing & Software, Inc. v. CommissionerUnited States Tax Court · 1975
- Briarcliff Candy Corporation, (Formerly Loft Candy Corporation) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
- Citizens & Southern Corp. v. CommissionerUnited States Tax Court · 1988
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