International Multifoods Corp. v. Commissioner
United States Tax Court
P was in the business of franchising the right to operate Mister Donut shops in the United States and abroad. On Jan. 31, 1989, P sold its Asian and Pacific Mister Donut business operations for $ 2,050,000. Pursuant to the agreement, P transferred its franchise agreements, trademarks, Mister Donut System, and goodwill for each of the Asian and Pacific countries in which P had existing franchise agreements, as well as its trademarks and Mister Donut System for those Asian and…
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P was in the business of franchising the right to operate Mister Donut shops in the United States and abroad. On Jan. 31, 1989, P sold its Asian and Pacific Mister Donut business operations for $ 2,050,000. Pursuant to the agreement, P transferred its franchise agreements, trademarks, Mister Donut System, and goodwill for each of the Asian and Pacific countries in which P had existing franchise agreements, as well as its trademarks and Mister Donut System for those Asian and Pacific countries in which it had registered trademarks but did not have franchise agreements. In the purchase…
1Opinion of the Court
INTERNATIONAL MULTIFOODS CORPORATION AND AFFILIATED COMPANIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
International Multifoods Corp. v. Commissioner
Docket No. 11643-92.
United States Tax Court
108 T.C. 25; 1997 U.S. Tax Ct. LEXIS 3; 108 T.C. No. 3;
January 29, 1997, Filed
P was in the business of franchising the right to operate Mister Donut shops in the United States and abroad. On Jan. 31, 1989, P sold its Asian and Pacific Mister Donut business operations for $ 2,050,000. Pursuant to the agreement, P transferred its franchise agreements, trademarks, Mister Donut System, and…
2Cases cited28 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- National Labor Relations Board v. Amax Coal Co.Supreme Court of the United States · 1981
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
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