Legal Opinion

Canterbury v. Commissioner

United States Tax Court

Decided August 17, 1992No. Docket Nos. 38037-87, 31477-88, 31478-88, 31479-88, 10551-89, 13576-89, 14540-89, 14849-89, 15037-89, 15038-89, 16033-89Published

Ps purchased existing McDonald's restaurant operations, including McDonald's franchise rights, from McDonald's franchisees. In each instance, the purchase price was in excess of the value of the tangible assets purchased. Ps allocated the portion of the purchase price which exceeded the value of the tangible assets to the franchise. Ps amortized the amount which they attributed to the franchise pursuant to sec. 1253(d)(2)(A), I.R.C.

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Ps purchased existing McDonald's restaurant operations, including McDonald's franchise rights, from McDonald's franchisees. In each instance, the purchase price was in excess of the value of the tangible assets purchased. Ps allocated the portion of the purchase price which exceeded the value of the tangible assets to the franchise. Ps amortized the amount which they attributed to the franchise pursuant to sec. 1253(d)(2)(A), I.R.C. R determined that Ps allocated too much of the cost of intangible assets to the franchise, that most of the cost of intangible assets should be allocated to…

1Opinion of the Court

Charles D. Canterbury and Diane M. Canterbury, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Canterbury v. Commissioner

Docket Nos. 38037-87, 31477-88, 31478-88, 31479-88, 10551-89, 13576-89, 14540-89, 14849-89, 15037-89, 15038-89, 16033-89

United States Tax Court

99 T.C. 223; 1992 U.S. Tax Ct. LEXIS 64; 99 T.C. No. 12;

August 17, 1992, Filed

Decisions will be entered under Rule 155 in docket Nos. 38037-87, 31478-88, 31479-88, 13576-89, and 15038-89. An appropriate order will be issued in docket Nos. 31477-88, 10551-89, 14540-89, 14849-89, 15037-89, and 16033-89.

Ps purchased…

2Cases cited36 opinions

  1. Arkansas v. OklahomaSupreme Court of the United States · 1992
  2. Rowan Cos. v. United StatesSupreme Court of the United States · 1981
  3. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  4. Helvering v. Bankline Oil Co.Supreme Court of the United States · 1938
  5. Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962

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