Legal Opinion
Marte A. Formico and Eula J. Formico v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided January 30, 1974No. 71-2882PublishedCited by 2 opinions
1Opinion of the Court
OPINION
SNEED, Circuit Judge:
This appeal involves, a disputed deficiency in the income taxes paid by Eula and Marte Formico (“Taxpayer”) 1 for the calendar years 1966 and 1967 in the amounts of $3,836.33 and $3,977.75 respectively. At issue here is whether the Tax Court erred in finding that Taxpayer had purchased solely “management rights” in connection with his acquisition of an insurance business, and that such rights were an intangible asset not subject to depreciation under Section 167(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 167(a).
In 1957, Grover M. Swofford was appointed a…
2Cases cited16 opinions
- Helvering v. WinmillSupreme Court of the United States · 1938
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- 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
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
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3Cited by2 opinions
- Sharon v. CommissionerUnited States Tax Court · 1976
- Sharon v. CommissionerUnited States Tax Court · 1976