Visador Co. v. Commissioner
United States Tax Court
In 1961 petitioner's predecessor partnership purchased all of the capital stock of Quality Door-Lite and Louver, Inc., for a stated purchase price of $325,000 plus the net worth of Quality, and also by separate contract acquired a covenant not to compete from Quality's two stockholders for a stated consideration of $25,000. Held, petitioner has failed to show by strong proof that the $325,000 was paid for the covenant not to compete.
1Opinion of the Court
VISADOR COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Visador Co. v. Commissioner
Docket No. 316-72
United States Tax Court
T.C. Memo 1973-173; 1973 Tax Ct. Memo LEXIS 118; 32 T.C.M. (CCH) 825; T.C.M. (RIA) 73173;
August 6, 1973, Filed
In 1961 petitioner's predecessor partnership purchased all of the capital stock of Quality Door-Lite and Louver, Inc., for a stated purchase price of $325,000 plus the net worth of Quality, and also by separate contract acquired a covenant not to compete from Quality's two stockholders for a stated consideration of $25,000. Held, petitioner has…
2Cases cited10 opinions
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Charles W. Balthrope and Mary v. Balthrope v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Emmette L. Barran and Martha Barran v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
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