Legal Opinion

Import Specialties, Inc. v. Commissioner

United States Tax Court

Decided January 29, 1982No. Docket Nos. 12890-78, 12971-78, 12972-78, 12973-78UnpublishedCited by 1 opinion

In 1971, Old Import, a corporation engaged in the wholesale costume jewelry business, sold its assets to Import Specialties. At the same time, two key employees of Old Import entered into employment contracts and covenants not to compete with Import Specialties.

Read the full summary

In 1971, Old Import, a corporation engaged in the wholesale costume jewelry business, sold its assets to Import Specialties. At the same time, two key employees of Old Import entered into employment contracts and covenants not to compete with Import Specialties. Held, the payments made by Import Specialties to the two employees did not constitute disguised payments for the goodwill of Old Import and therefore are deductible as compensation and as the amortized cost of covenants not to compete. Held further, Import Specialties improperly reduced its inventories under the lower of cost or…

1Opinion of the Court

IMPORT SPECIALTIES, INC. (NOW KNOWN AS IMPORT LIMITED), ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Import Specialties, Inc. v. Commissioner

Docket Nos. 12890-78, 12971-78, 12972-78, 12973-78

United States Tax Court

T.C. Memo 1982-41; 1982 Tax Ct. Memo LEXIS 708; 43 T.C.M. (CCH) 411; T.C.M. (RIA) 82041;

January 29, 1982.

In 1971, Old Import, a corporation engaged in the wholesale costume jewelry business, sold its assets to Import Specialties. At the same time, two key employees of Old Import entered into employment contracts and covenants not to compete with Import…

2Cases cited22 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  4. Griffiths v. CommissionerSupreme Court of the United States · 1939
  5. Lucas v. Kansas City Structural Steel Co.Supreme Court of the United States · 1930

17 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Estate of Morris v. CommissionerUnited States Tax Court · 1983

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API