Stiles v. Commissioner
United States Tax Court
Petitioner purchased a trade name including any goodwill attached thereto, and as a sole proprietor doing business under that name promoted the sales of a device for blending colors of paint. Sales were made in the years 1960 through 1965. Held: The installment payments made in 1961 and 1962 for the trade name were for acquiring a capital asset and are not deductible as ordinary and necessary business expenses, nor as depreciation.
1Opinion of the Court
Harold M. Stiles and Margaret M. Stiles, Husband and Wife v. Commissioner.
Stiles v. Commissioner
Docket No. 2177-65.
United States Tax Court
T.C. Memo 1967-106; 1967 Tax Ct. Memo LEXIS 152; 26 T.C.M. (CCH) 501; T.C.M. (RIA) 67106;
May 12, 1967
Petitioner purchased a trade name including any goodwill attached thereto, and as a sole proprietor doing business under that name promoted the sales of a device for blending colors of paint. Sales were made in the years 1960 through 1965.
Held: The installment payments made in 1961 and 1962 for the trade name were for acquiring a capital asset and are not…
2Cases cited5 opinions
- Michaels v. CommissionerUnited States Tax Court · 1949
- Horton v. CommissionerUnited States Tax Court · 1949
- Seattle Brewing & Malting Co. v. Comm'rUnited States Tax Court · 1946
- Imperial Type Metal Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1939
- Sevremes v. United StatesDistrict Court, W.D. Kentucky · 1962