Manhattan Co. of Virginia, Inc. v. Commissioner
United States Tax Court
Petitioners purchased the names and addresses of a number of home pickup-and-delivery laundry customers from another laundry company. No goodwill of any other character was purchased, and the other laundry company continued with all other facets of its business. Covenants not to compete were also purchased by petitioners in the same transaction. Held: Petitioners are not entitled to deductions in the year of purchase for the entire cost of the customer lists.
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Petitioners purchased the names and addresses of a number of home pickup-and-delivery laundry customers from another laundry company. No goodwill of any other character was purchased, and the other laundry company continued with all other facets of its business. Covenants not to compete were also purchased by petitioners in the same transaction. Held: Petitioners are not entitled to deductions in the year of purchase for the entire cost of the customer lists. The information contained on the lists constituted intangible assets, portions of which were in the nature of nondepreciable goodwill…
1Opinion of the Court
Manhattan Company of Virginia, Incorporated (a Dissolved Corporation), Petitioner v. Commissioner of Internal Revenue, Respondent; Manhattan Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Manhattan Co. of Virginia, Inc. v. Commissioner
Docket Nos. 3535-65, 7097-65
United States Tax Court
50 T.C. 78; 1968 U.S. Tax Ct. LEXIS 141;
April 17, 1968, Filed
Decisions will be entered under Rule 50.
Petitioners purchased the names and addresses of a number of home pickup-and-delivery laundry customers from another laundry company. No goodwill of any other character was purchased, and the…
Also in this document: Concurrence · Drennen; Concurrence · Simpson; Dissent.
2Cases cited21 opinions
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Boe v. CommissionerUnited States Tax Court · 1961
- Commissioner of Internal Revenue v. Liberty Bank & Trust Co.Court of Appeals for the Sixth Circuit · 1932
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