Massey-Ferguson, Inc. v. Commissioner
United States Tax Court
In 1957, P purchased all of the tangible and intangible assets of MI, including trade names, a product line, the general line distributorship system, and the going-concern value of the MI operation. P continued the MI operation as its industrial division until 1961, when it terminated the operation, eliminated the last of the general line distributors, and discontinued using a trade name.
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In 1957, P purchased all of the tangible and intangible assets of MI, including trade names, a product line, the general line distributorship system, and the going-concern value of the MI operation. P continued the MI operation as its industrial division until 1961, when it terminated the operation, eliminated the last of the general line distributors, and discontinued using a trade name. After 1961, P continued to manufacture similar products elsewhere under its own name and maintained its own sales system. Held, (1) in 1961, P abandoned a certain trade name, the general line distributorship…
1Opinion of the Court
Simpson, Judge:
The respondent determined a deficiency of $17,811 in the petitioner’s 1961 Federal income tax. The only issue for decision is whether the petitioner is entitled to a loss for the abandonment of certain intangible assets in 1961.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The petitioner, Massey-Ferguson, Inc. (M-F, Inc.), is a Maryland corporation, which had its principal place of business in Des Moines, Iowa, at the time of the filing of its petition in this case. It filed its Federal income tax return for the taxable year ended October…
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- Commissioner of Internal Revenue v. Indiana Broadcasting CorporationCourt of Appeals for the Seventh Circuit · 1965
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