Legal Opinion

Cutler v. Commissioner

United States Tax Court

Decided September 19, 1977No. Docket No. 2219-75Unpublished

Petitioners purchased a produce brokerage company for $20,000 under a sales contract which did not contain a covenant not to compete. Held, petitioners are not entitled to a deduction for any portion of the purchase price allegedly allocable to such a covenant. Heldfurther, petitioners are not entitled to a deduction under sec. 248, I.R.C. 1954.

1Opinion of the Court

PHILIP L. CUTLER and SARITA B. CUTLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cutler v. Commissioner

Docket No. 2219-75.

United States Tax Court

T.C. Memo 1977-320; 1977 Tax Ct. Memo LEXIS 128; 36 T.C.M. (CCH) 1290; T.C.M. (RIA) 770320;

September 19, 1977, Filed

Petitioners purchased a produce brokerage company for $20,000 under a sales contract which did not contain a covenant not to compete. Held, petitioners are not entitled to a deduction for any portion of the purchase price allegedly allocable to such a covenant. Heldfurther, petitioners are not entitled to a deduction…

2Cases cited9 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
  3. Danielson v. CommissionerUnited States Tax Court · 1965
  4. Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
  5. Schmitz v. CommissionerUnited States Tax Court · 1968

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