Legal Opinion

Martin Ice Cream Co. v. Comm'r

United States Tax Court

Decided March 17, 1998No. Tax Ct. Dkt. No. 1477-93Published

A and his son M were shareholders of MIC, an S corporation that distributed ice cream products to supermarket chains, independent grocery stores, and food service accounts. MIC's supermarket business was largely attributable to the close personal relationships that A had developed and maintained for decades, beginning before the creation of MIC in 1971, with the owners and managers of the supermarket chains.

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A and his son M were shareholders of MIC, an S corporation that distributed ice cream products to supermarket chains, independent grocery stores, and food service accounts. MIC's supermarket business was largely attributable to the close personal relationships that A had developed and maintained for decades, beginning before the creation of MIC in 1971, with the owners and managers of the supermarket chains. Since 1974, MIC had distributed the ice cream products of HD, pursuant to an oral agreement entered into between A and the founder of HD. In 1987 and 1988, following the acquisition of HD…

1Opinion of the Court

MARTIN ICE CREAM COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Martin Ice Cream Co. v. Comm'r

Tax Ct. Dkt. No. 1477-93

United States Tax Court

110 T.C. 189; 1998 U.S. Tax Ct. LEXIS 17; 110 T.C. No. 18;

March 17, 1998, Filed

Decision will be entered under Rule 155.

A and his son M were shareholders of MIC, an S corporation that distributed ice cream products to supermarket chains, independent grocery stores, and food service accounts. MIC's supermarket business was largely attributable to the close personal relationships that A had developed and maintained for decades, beginning…

2Cases cited75 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. United States v. BoyleSupreme Court of the United States · 1985
  3. United States v. CartwrightSupreme Court of the United States · 1973
  4. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  5. United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950

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