Legal Opinion
James A. Patterson and Dorothy A. Patterson v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided February 2, 1987No. 85-1904PublishedCited by 37 opinions
1Opinion of the Court
RALPH B. GUY, Jr., Circuit Judge.
This case involves a dispute as to the amount, if any, of the consideration received for a sale of stock that is properly allocable to a covenant not to compete. The Tax Court held in favor of the taxpayer, Patterson, concluding that he had correctly allocated the entire sale price to the sale of stock. The Commissioner filed a timely appeal. For the reasons set forth below, the decision of the Tax Court is affirmed.
I
The facts of this case, some of which were stipulated, may be summarized as follows:
Taxpayer, Patterson, has a degree in marketing from the…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Schulz v. CommissionerCourt of Appeals for the Ninth Circuit · 1961
10 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- North American Rayon Corporation, Formerly Known as North American Holding Corporation, Narco v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
- Muskat v. United StatesCourt of Appeals for the First Circuit · 2009
- Warren L. Baker, Jr. And Dorris J. Baker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2003
- Ohio Farm Bureau Fed'n v. CommissionerUnited States Tax Court · 1996
- Citibank (South Dakota), N.A. v. Federal Deposit InsuranceDistrict Court, District of Columbia · 1993
32 more not listed; retrieve them via the Exa API.