Ithaca Indus. v. Commissioner
United States Tax Court
P purchased the stock of a corporation which it then liquidated. P allocated the price of the stock among the assets it acquired, including an asset it designated as an "assembled work force" and an asset it designated as "raw material contracts." Held, the assembled work force is not a wasting asset separate and distinct from goodwill and going-concern value and therefore may not be amortized.
Read the full summary
P purchased the stock of a corporation which it then liquidated. P allocated the price of the stock among the assets it acquired, including an asset it designated as an "assembled work force" and an asset it designated as "raw material contracts." Held, the assembled work force is not a wasting asset separate and distinct from goodwill and going-concern value and therefore may not be amortized. Held further, the raw material contracts have a limited useful life of 14 months and an ascertainable value separate and distinct from goodwill and going-concern value, which value may be amortized…
1Opinion of the Court
SCOTT, Judge:
Respondent determined deficiencies in petitioner’s corporate income tax for its fiscal years ending February 3, 1984, and February 1, 1985, in the amounts of $404,290 and $572,775, respectively. The issues for decision are: (1) Whether an assembled work force is an intangible asset distinct from goodwill or going-concern value with an ascertainable useful life over which the value of the asset may be amortizable; (2) whether raw material supply contracts are assets distinct from goodwill or going-concern value with an ascertainable useful life over which the value of the asset…
2Cases cited28 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- 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
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
23 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
- Ithaca Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1994
- Capital Blue Cross and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2005
- Veritas Software Corp. v. Comm'rUnited States Tax Court · 2009
- Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
15 more not listed; retrieve them via the Exa API.