Legal Opinion
Frontier Chevrolet Company v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 28, 2003No. 01-71815PublishedCited by 11 opinions
1Opinion of the Court
OPINION
TROTT, Circuit Judge:
Frontier Chevrolet Company (“Frontier”) appeals the tax court’s decision that I.R.C. § 197 (“ § 197”) applied to a covenant not to compete entered into in connection with Frontier’s redemption of 75% of its stock. We agree with the tax court that Frontier’s redemption was an indirect acquisition of an interest in a trade or business; therefore Frontier had to amortize the covenant under § 197.
BACKGROUND
A
The facts are set forth as stipulated by the parties before the tax court. At the time Frontier filed its petition with the Tax court, it was a corporation with its…
2Cited by11 opinions
- H.J. Heinz Co. & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2007
- Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
- Recovery Group, Inc. v. CommissionerCourt of Appeals for the First Circuit · 2011
- Stanley T. Johnson Constance Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2006
- Recovery Group, Inc. v. Comm'rUnited States Tax Court · 2010
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