Cunningham v. Commissioner
United States Tax Court
Random provided computerized single-entry bookkeeping services to the public. In late 1979, P and Random executed a License Service Agreement under which P was to pay $ 24,000 to Random and Random was to pay to P certain amounts over time, depending on the volume of Random's business in Cincinnati, Ohio. P paid part of the $ 24,000 to Random in early 1980. Neither P nor Random paid anything else to the other pursuant to this agreement.
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Random provided computerized single-entry bookkeeping services to the public. In late 1979, P and Random executed a License Service Agreement under which P was to pay $ 24,000 to Random and Random was to pay to P certain amounts over time, depending on the volume of Random's business in Cincinnati, Ohio. P paid part of the $ 24,000 to Random in early 1980. Neither P nor Random paid anything else to the other pursuant to this agreement. P deducted the entire $ 24,000 for 1979. This agreement provides that if the agreement were not renewed, then Random would buy back P's rights under this…
1Opinion of the Court
CHARLES CUNNINGHAM AND ROSE M. CURLESS, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cunningham v. Commissioner
Docket Nos. 18093-83; 18672-83; 24602-83.
United States Tax Court
T.C. Memo 1989-260; 1989 Tax Ct. Memo LEXIS 260; 57 T.C.M. (CCH) 547; T.C.M. (RIA) 89260;
May 30, 1989.
Random provided computerized single-entry bookkeeping services to the public. In late 1979, P and Random executed a License Service Agreement under which P was to pay $ 24,000 to Random and Random was to pay to P certain amounts over time, depending on the volume of Random's business in…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Solowiejczyk v. CommissionerUnited States Tax Court · 1985
- Reiff v. CommissionerUnited States Tax Court · 1981
- Rybak v. CommissionerUnited States Tax Court · 1988
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