Jorgl v. Commissioner
United States Tax Court
Ps, husband and wife, operated a child care business of which P husband was the sole shareholder. P subsequently established a charitable remainder unitrust and contributed all of his shares in the child care business to the trust. The trust later sold the business and received all proceeds of the sale.
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Ps, husband and wife, operated a child care business of which P husband was the sole shareholder. P subsequently established a charitable remainder unitrust and contributed all of his shares in the child care business to the trust. The trust later sold the business and received all proceeds of the sale. The purchase agreement between the trust and the buyers contained a covenant not to compete, and Ps signed a separate document entitled "COVENANT NOT TO COMPETE" at the time of sale. Ps reported no income as a result of this transaction, and R determined a deficiency for taxes attributable to…
1Opinion of the Court
JOHN T. JORGL AND SHARON ILLI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Jorgl v. Commissioner
No. 11508-98
United States Tax Court
T.C. Memo 2000-10; 2000 Tax Ct. Memo LEXIS 10; 79 T.C.M. (CCH) 1318;
January 11, 2000, Filed
Decision will be entered under Rule 155.
Ps, husband and wife, operated a child care business of
which P husband was the sole shareholder. P subsequently
established a charitable remainder unitrust and contributed
all of his shares in the child care business to the trust.
The trust later sold the business and received all proceeds
of the sale. The purchase agreement…
2Cases cited30 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Lucas v. EarlSupreme Court of the United States · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Freytag v. CommissionerSupreme Court of the United States · 1991
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