Meredith Corp. v. Commissioner
United States Tax Court
P purchased all of the assets of a consumer magazine business. As part of the purchase, P became the employer of E and acquired subscriber relationships and subscription lists. The purchase agreement made no allocation of consideration among the acquired assets. Noncompetition agreements were executed at the time of the purchase by the selling corporation and its majority shareholder.
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P purchased all of the assets of a consumer magazine business. As part of the purchase, P became the employer of E and acquired subscriber relationships and subscription lists. The purchase agreement made no allocation of consideration among the acquired assets. Noncompetition agreements were executed at the time of the purchase by the selling corporation and its majority shareholder. The noncompetition agreements unambiguously recited the amounts of consideration paid for each. 1. Held, P has failed to establish the remaining useful life and value of the employment relationship with E. 2.…
1Opinion of the Court
Nims, Judge:
Respondent determined deficiencies in Federal income tax with respect to petitioner’s fiscal year ended June 30, 1986 (FYE 1986), in the amount of $6,466,674.82, and with respect to petitioner’s fiscal year ended June 30, 1987 (fye 1987), in the amount of $11,493,459. In addition to contesting these deficiencies, petitioner claims overpay-ments in Federal income tax with respect to FYE 1986 in the amount of $4,760,484 and with respect to fye 1987 in the amount of $5,033,291.
Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect…
2Cases cited38 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. CartwrightSupreme Court of the United States · 1973
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
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3Cited by23 opinions
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- Hess v. Comm'rUnited States Tax Court · 2003
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