R. M. Smith, Inc. v. Commissioner
United States Tax Court
Following the filing of our opinion in this case, T. C. Memo. 1977-23, the parties submitted conflicting computations of tax under Rule 155. The points of disagreement between the parties, involving for the most part an interpretation of the regulations under sec. 334(b)(2), I.R.C. 1954, have raised various questions which were not presented to the Court in the original proceedings. See n. 17 in our prior opinion.
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Following the filing of our opinion in this case, T. C. Memo. 1977-23, the parties submitted conflicting computations of tax under Rule 155. The points of disagreement between the parties, involving for the most part an interpretation of the regulations under sec. 334(b)(2), I.R.C. 1954, have raised various questions which were not presented to the Court in the original proceedings. See n. 17 in our prior opinion. Upon consideration of the parties' arguments, it is Held: 1. In applying the residual method of valuing intangibles, the known fair market values of the tangible assets are…
1Opinion of the Court
SUPPLEMENTAL OPINION
Drennen, Judge:
The opinion in this case (T.C. Memo. 1977-23) was filed on January 31,1977. In accordance with Rule 155, Tax Court Rules of Practice and Procedure, respondent filed Respondent’s Computation for Entry of Decision on April 6, 1977, and petitioner filed Petitioner’s Computation of Tax Pursuant to Decision on April 26, 1977. Because the parties differed in their computations, a hearing was held on May 4, 1977, pursuant to Rule 155(b).
Subsequent to that hearing, with the leave of the Court, petitioner filed Petitioner’s Memorandum Brief Supporting Rule 155…
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