Lazisky v. Commissioner
United States Tax Court
Allocation of purchase price between goodwill and covenant not to compete determined. "Strong-proof" doctrine applied. Harvey Radio Laboratories, Inc. v. Commissioner, 470 F.2d 118 (1st Cir. 1972). Word "order" for purposes of sec. 50(a)(2)(B), I.R.C. 1954, and the investment credit defined. Sec. 50(a)(2)(B) applied.
1Opinion of the Court
Sterrett, Judge:
In a notice of deficiency dated October 4, 1976, respondent determined a deficiency in income taxes paid by petitioners Albert A. Lazisky and Elizabeth Lazisky, docket No. 11004r-76, for their taxable year ended December 31,1971, in the amount of $30,724.52. In a notice of deficiency dated October 4,1976, respondent determined deficiencies in income taxes paid by petitioner Magnolia Surf, Inc., docket No. 170-77, for its taxable years ended March 31, 1972 and 1974, in the respective amounts of $8,113 and $2,517.75. After concessions the only remaining issues for our decision…
2Cases cited12 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Alfred Dunhill of London, Inc. v. Republic of CubaSupreme Court of the United States · 1976
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Schulz v. CommissionerCourt of Appeals for the Ninth Circuit · 1961
- Annabelle Candy Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
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3Cited by35 opinions
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- Better Beverages, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1980
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