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