AMDAHL CORP. v. COMMISSIONER
United States Tax Court
P paid relocation expenses of its employees and provided financial assistance in connection with the sale of their residences. P contracted with relocation service companies (RSC) to manage the sale of the employees' residences. The RSC paid the employees their equity in their homes and paid the costs of maintaining the residences, including mortgage and property tax expenses, until third parties purchased the residences.
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P paid relocation expenses of its employees and provided financial assistance in connection with the sale of their residences. P contracted with relocation service companies (RSC) to manage the sale of the employees' residences. The RSC paid the employees their equity in their homes and paid the costs of maintaining the residences, including mortgage and property tax expenses, until third parties purchased the residences. P reimbursed the RSC for its expenses and paid the RSC a fee. The relocating employees retained legal title to the residences. R disallowed a deduction to P for certain…
1Opinion of the Court
Gerber, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
TYE Deficiency
12/30/83 . $25,528,729
12/28/84 . 6,245,206
12/27/85 . 4,394,198
12/26/86 . 4,038,178
After concessions, the issue for decision is whether payments made by petitioner to relocation service companies to assist in the disposition of the homes of its employees who relocate in connection with their employment are deductible against ordinary income or must be treated as a capital loss.
FINDINGS OF FACT1
Petitioner is a Delaware corporation with its principal place of business in Sunnyvale,…
2Cases cited18 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- Sanford v. CommissionerUnited States Tax Court · 1968
13 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Stuart v. CommissionerUnited States Tax Court · 2015
- AMDAHL CORP. v. COMMISSIONERUnited States Tax Court · 1997