International Multifoods Corp. v. Commissioner
United States Tax Court
P was in the business of franchising the right to operate Mister Donut shops in the United States and abroad. On Jan. 31, 1989, P sold its Asian and Pacific Mister Donut business operations for $ 2,050,000. Pursuant to the agreement, P transferred its franchise agreements, trademarks, Mister Donut System, and goodwill for each of the Asian and Pacific countries in which P had existing franchise agreements, as well as its trademarks and Mister Donut System for those Asian and…
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P was in the business of franchising the right to operate Mister Donut shops in the United States and abroad. On Jan. 31, 1989, P sold its Asian and Pacific Mister Donut business operations for $ 2,050,000. Pursuant to the agreement, P transferred its franchise agreements, trademarks, Mister Donut System, and goodwill for each of the Asian and Pacific countries in which P had existing franchise agreements, as well as its trademarks and Mister Donut System for those Asian and Pacific countries in which it had registered trademarks but did not have franchise agreements. In the purchase…
1Opinion of the Court
Ruwe, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
TYE Deficiency
2/28/87 . $2,962,380
2/29/88 . 3,592,402
Petitioner paid these deficiencies following receipt of its notice of deficiency and then filed a petition with this Court claiming an overpayment of income tax for each year. On December 6, 1993, petitioner filed a motion for leave to amend petition in order to claim an increased overpayment of income tax for its taxable year ended February 28, 1987, resulting from, among other things, an alleged foreign tax credit carryback from its taxable year…
2Cases cited28 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- National Labor Relations Board v. Amax Coal Co.Supreme Court of the United States · 1981
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
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3Cited by6 opinions
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- International Multifoods Corporation and Affiliated Companies v. CommissionerUnited States Tax Court · 1997
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