Washington Package Store, Inc. v. Commissioner
United States Tax Court
1. Held, on the facts, that no part of the consideration paid by petitioner as the purchase price for the going business of a retail liquor store, is properly allocable to the leasehold occupied by such business; and that petitioner is not entitled to an amortization deduction in respect of a claimed cost for said leasehold. 2. Held, that petitioner did not realize any taxable income as a result of a transaction whereby it relinquished its rights under a covenant not to…
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1. Held, on the facts, that no part of the consideration paid by petitioner as the purchase price for the going business of a retail liquor store, is properly allocable to the leasehold occupied by such business; and that petitioner is not entitled to an amortization deduction in respect of a claimed cost for said leasehold. 2. Held, that petitioner did not realize any taxable income as a result of a transaction whereby it relinquished its rights under a covenant not to compete executed by the seller of the liquor store, and said seller cancelled certain notes payable issued by petitioner in…
1Opinion of the Court
Washington Package Store, Inc. v. Commissioner.
Washington Package Store, Inc. v. Commissioner
Docket No. 93915.
United States Tax Court
T.C. Memo 1964-294; 1964 Tax Ct. Memo LEXIS 44; 23 T.C.M. (CCH) 1805; T.C.M. (RIA) 64294;
November 12, 1964
1. Held, on the facts, that no part of the consideration paid by petitioner as the purchase price for the going business of a retail liquor store, is properly allocable to the leasehold occupied by such business; and that petitioner is not entitled to an amortization deduction in respect of a claimed cost for said leasehold.
2. Held, that petitioner did not…
2Cases cited6 opinions
- Copperhead Coal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959
- Atterbury v. CommissionerUnited States Board of Tax Appeals · 1924
- Thomas v. CommissionerUnited States Tax Court · 1959
- Newman v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1930
- Cooper Foundation, a Corporation v. George W. O'MalleyCourt of Appeals for the Eighth Circuit · 1955
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