Solitron Devices, Inc. v. Commissioner
United States Tax Court
Petitioner was engaged in the business of designing, manufacturing, and marketing electronic components. In 1968, it decided to enter the microwave industry. After several unsuccessful attempts to acquire large microwave manufacturing companies, petitioner began to acquire a number of smaller companies which collectively could offer the broad product mix of the larger competitors.
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Petitioner was engaged in the business of designing, manufacturing, and marketing electronic components. In 1968, it decided to enter the microwave industry. After several unsuccessful attempts to acquire large microwave manufacturing companies, petitioner began to acquire a number of smaller companies which collectively could offer the broad product mix of the larger competitors. Pursuant to this strategy, petitioner purchased GRFF, a manufacturer primarily engaged in the custom connector business. After abbreviated negotiations, petitioner purchased all of the stock of GRFF on Aug. 29,…
1Opinion of the Court
Sterrett, Judge:
By notice of deficiency dated April 20, 1978, respondent determined a deficiency in petitioner’s Federal income tax for the taxable year ended February 28, 1970, in the amount of $981,762. The issues for decision are (1) whether petitioner purchased certain intangible assets previously held by General RF Fittings, Inc. (hereinafter GRFF), upon its acquisition of the stock of GRFF or whether petitioner created such intangible assets in itself by such acquisition; (2) whether, upon liquidation of GRFF, petitioner received such intangible assets to which it must allocate the…
2Cases cited44 opinions
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- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
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