Concord Control, Inc. v. Commissioner
United States Tax Court
In Concord Control, Inc. v. Commissioner, T.C. Memo. 1976-301, this Court held that no goodwill was acquired by petitioner in its 1964 purchase of K-D. However, we held that part of the purchase price was attributable to nondepreciable going concern value, and we estimated such amount. The U.S.
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In Concord Control, Inc. v. Commissioner, T.C. Memo. 1976-301, this Court held that no goodwill was acquired by petitioner in its 1964 purchase of K-D. However, we held that part of the purchase price was attributable to nondepreciable going concern value, and we estimated such amount. The U.S. Court of Appeals for the Sixth Circuit affirmed our holding with respect to the existence of going-concern value, but remanded the case for us to explain our method of calculating the amount of going-concern value and why we chose that method. Held, using the capitalization of earnings method, the…
1Opinion of the Court
SUPPLEMENTAL OPINION
Sterrett, Judge:
In its Memorandum Findings of Fact and Opinion (T.C. Memo. 1976-301), filed September 27,1976, this Court examined the acquisition in February 1964 by petitioner’s predecessor in interest of the K-D Lamp Division (hereinafter K-D) from the Duplan Corp. (hereinafter Duplan). K-D was involved in the manufacture and sale of automotive safety equipment. In our opinion, we sustained petitioner’s assertion that the negotiations leading to the sale were conducted in good faith and at arm’s length between unrelated parties. However, we found that the parties to the…
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- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
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- Elmhurst Cemetery Co. of Joliet v. CommissionerSupreme Court of the United States · 1937
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
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