Legal Opinion

National Starch & Chemical Corp. v. Commissioner

United States Tax Court

Decided July 24, 1989No. Docket No. 31669-84Published

P, the acquired firm in a friendly takeover, incurred legal, investment banking, and other fees incident to the takeover. Held, the fees are capital expenditures rather than current expenses and, thus, are not deductible under sec. 162(a).

1Opinion of the Court

National Starch and Chemical Corp., Petitioner v. Commissioner of Internal Revenue, Respondent

National Starch & Chemical Corp. v. Commissioner

Docket No. 31669-84

United States Tax Court

93 T.C. 67; 1989 U.S. Tax Ct. LEXIS 103; 93 T.C. No. 7;

July 24, 1989July 24, 1989, Filed

Decision will be entered for the respondent.

P, the acquired firm in a friendly takeover, incurred legal, investment banking, and other fees incident to the takeover. Held, the fees are capital expenditures rather than current expenses and, thus, are not deductible under sec. 162(a).

Richard J. Hiegel, Leonard E. Kust, Richard…

2Cases cited35 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  3. Unocal Corp. v. Mesa Petroleum Co.Supreme Court of Delaware · 1985
  4. Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
  5. McDonald v. CommissionerSupreme Court of the United States · 1944

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