Legal Opinion
Frontier Chevrolet Co. v. Commissioner
United States Tax Court
Decided May 14, 2001No. Docket 19627-98Unknown
1Opinion of the Court
OPINION
Ruwe, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
Year Amount
1994 . $28,996
1995 . 135,880
1996 . 110,320
After concessions, 1 the issue for decision is whether petitioner must amortize noncompetition agreement payments over 15 years pursuant to section 197. 2
Background,
The parties submitted this case fully stipulated. The stipulation of facts, the stipulation of settled issues, and the attached exhibits are incorporated herein by this reference. Petitioner is a corporation that had its principal place of business in Billings, Montana, at the…
2Cases cited9 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
- Boyle v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1951
- Spencer v. CommissionerUnited States Tax Court · 1998
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