Legal Opinion

R. M. Smith, Inc. v. Commissioner

United States Tax Court

Decided November 29, 1977No. Docket No. 478-74Published

Following the filing of our opinion in this case, T. C. Memo. 1977-23, the parties submitted conflicting computations of tax under Rule 155. The points of disagreement between the parties, involving for the most part an interpretation of the regulations under sec. 334(b)(2), I.R.C. 1954, have raised various questions which were not presented to the Court in the original proceedings. See n. 17 in our prior opinion.

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Following the filing of our opinion in this case, T. C. Memo. 1977-23, the parties submitted conflicting computations of tax under Rule 155. The points of disagreement between the parties, involving for the most part an interpretation of the regulations under sec. 334(b)(2), I.R.C. 1954, have raised various questions which were not presented to the Court in the original proceedings. See n. 17 in our prior opinion. Upon consideration of the parties' arguments, it is Held: 1. In applying the residual method of valuing intangibles, the known fair market values of the tangible assets are…

1Opinion of the Court

R. M. Smith, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

R. M. Smith, Inc. v. Commissioner

Docket No. 478-74

United States Tax Court

69 T.C. 317; 1977 U.S. Tax Ct. LEXIS 17;

November 29, 1977, Filed

Following the filing of our opinion in this case, T. C. Memo. 1977-23, the parties submitted conflicting computations of tax under Rule 155. The points of disagreement between the parties, involving for the most part an interpretation of the regulations under sec. 334(b)(2), I.R.C. 1954, have raised various questions which were not presented to the Court in the original proceedings.…

2Cases cited16 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
  3. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
  4. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  5. Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946

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