Boe v. Commissioner
United States Tax Court
Petitioner Richard M. Boe was one of four partners who purchased a contract medical service organization, part of which consisted of 8,984 medical service contracts, and continued to operate the business.
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Petitioner Richard M. Boe was one of four partners who purchased a contract medical service organization, part of which consisted of 8,984 medical service contracts, and continued to operate the business. Held, petitioner bought a single intangible capital asset consisting of the aggregate of the 8,984 medical service contracts, and this asset had no limited or determinable useful life and could not be amortized under sec. 23(l), I.R.C. 1939, or sec. 167(a), I.R.C. 1954. Thrifticheck Service Corporation, 33 T.C. 1038, followed.
1Opinion of the Court
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners’ income tax for the taxable years 1952, 1953, and 1954 as follows:
Year Deficiency
1952_$20, 852.16
1953_ 2, 759.14
1954_ 6, 551. 33
The sole issue remaining for our consideration is whether petitioners may deduct the cost of medical service contracts which were terminated during each of the years before us, and if so, the cost of these contracts.
FINDINGS OF FACT.
Some of the facts have been stipulated and are incorporated herein by tliis reference.
Richard M. Boe, also known as M. Richard Boe, and Mary Lois Boe are husband and…
2Cases cited6 opinions
- Thrifticheck Service Corp. v. CommissionerUnited States Tax Court · 1960
- Anchor Cleaning Service, Inc. v. CommissionerUnited States Tax Court · 1954
- Houston Natural Gas Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1937
- Meredith Pub. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1933
- Metropolitan Laundry Co. v. United StatesDistrict Court, N.D. California · 1951
1 more not listed; retrieve them via the Exa API.
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- Indiana Broadcasting Corp. v. CommissionerUnited States Tax Court · 1964
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