Holden Fuel Oil Co. v. Commissioner
United States Tax Court
Petitioner was engaged in the retail sale of fuel oil. On February 18, 1959, it entered into a contract with Gulf wherein petitioner purchased a list of fuel oil customer accounts in the same general geographical location that petitioner was then serving.
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Petitioner was engaged in the retail sale of fuel oil. On February 18, 1959, it entered into a contract with Gulf wherein petitioner purchased a list of fuel oil customer accounts in the same general geographical location that petitioner was then serving. Held, Petitioner is not entitled to deduct the cost of the customer list as a business expense under sec. 162, I.R.C. 1954. Held further, the list is an intangible asset, 25 percent of which is in the nature of nondepreciable goodwill and 75 percent of which had a reasonably determinable useful life, entitling petitioner to depreciation…
1Opinion of the Court
Holden Fuel Oil Company v. Commissioner.
Holden Fuel Oil Co. v. Commissioner
Docket Nos. 929-65, 4286-70.
United States Tax Court
T.C. Memo 1972-45; 1972 Tax Ct. Memo LEXIS 209; 31 T.C.M. (CCH) 184; T.C.M. (RIA) 72045;
February 23, 1972, Filed
Petitioner was engaged in the retail sale of fuel oil. On February 18, 1959, it entered into a contract with Gulf wherein petitioner purchased a list of fuel oil customer accounts in the same general geographical location that petitioner was then serving. Held, Petitioner is not entitled to deduct the cost of the customer list as a business expense under sec.…
2Cases cited12 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- 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
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Boe v. CommissionerUnited States Tax Court · 1961
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