Ithaca Indus. v. Commissioner
United States Tax Court
P purchased the stock of a corporation which it then liquidated. P allocated the price of the stock among the assets it acquired, including an asset it designated as an "assembled work force" and an asset it designated as "raw material contracts." Held, the assembled work force is not a wasting asset separate and distinct from goodwill and going-concern value and therefore may not be amortized.
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P purchased the stock of a corporation which it then liquidated. P allocated the price of the stock among the assets it acquired, including an asset it designated as an "assembled work force" and an asset it designated as "raw material contracts." Held, the assembled work force is not a wasting asset separate and distinct from goodwill and going-concern value and therefore may not be amortized. Held further, the raw material contracts have a limited useful life of 14 months and an ascertainable value separate and distinct from goodwill and going-concern value, which value may be amortized…
1Opinion of the Court
ITHACA INDUSTRIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Ithaca Indus. v. Commissioner
Docket No. 7076-89
United States Tax Court
97 T.C. 253; 1991 U.S. Tax Ct. LEXIS 75; 97 T.C. No. 16;
August 12, 1991, Filed
Decision will be entered under Rule 155.
P purchased the stock of a corporation which it then liquidated. P allocated the price of the stock among the assets it acquired, including an asset it designated as an "assembled work force" and an asset it designated as "raw material contracts." Held, the assembled work force is not a wasting asset separate and distinct from…
2Cases cited29 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
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