Legal Opinion

Massey-Ferguson, Inc. v. Commissioner

United States Tax Court

Decided November 8, 1972No. Docket No. 2923-70PublishedCited by 30 opinions

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…

2Cases cited15 opinions

  1. United States v. DavisSupreme Court of the United States · 1962
  2. Parmelee Transportation Company v. The United StatesUnited States Court of Claims · 1965
  3. W. B. Davis & Son, Inc. v. CommissionerUnited States Tax Court · 1945
  4. Commissioner of Internal Revenue v. Boston Elevated Ry. CoCourt of Appeals for the First Circuit · 1952
  5. Commissioner of Internal Revenue v. Indiana Broadcasting CorporationCourt of Appeals for the Seventh Circuit · 1965

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

3Cited by30 opinions

  1. Brountas v. CommissionerUnited States Tax Court · 1979
  2. Paul P. Brountas v. Commissioner of Internal Revenue, Paul P. And Lynn T. Brountas v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1982
  3. Crc Corporation v. Commissioner of Internal Revenue. Crc Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1982
  4. Ferrell v. CommissionerUnited States Tax Court · 1988
  5. Solitron Devices, Inc. v. CommissionerUnited States Tax Court · 1983

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

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