Legal Opinion

Peerless Inv. Co. v. Commissioner

United States Tax Court

Decided August 28, 1972No. Docket No. 1819-70Published

In 1950, the petitioner purchased all the stock of Packing, paying approximately $ 200,000 in excess of the fair market value of the underlying assets. In 1963, Packing was merged into the petitioner, and at that time, Packing had no basis for Federal income tax purposes for goodwill. In 1966, the petitioner sold its assets and deducted a loss for goodwill equal to the amount that it paid in excess of the fair market value of the assets.

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In 1950, the petitioner purchased all the stock of Packing, paying approximately $ 200,000 in excess of the fair market value of the underlying assets. In 1963, Packing was merged into the petitioner, and at that time, Packing had no basis for Federal income tax purposes for goodwill. In 1966, the petitioner sold its assets and deducted a loss for goodwill equal to the amount that it paid in excess of the fair market value of the assets. Held, in 1950, the petitioner purchased stock; it did not purchase goodwill and stock.

1Opinion of the Court

Peerless Investment Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Peerless Inv. Co. v. Commissioner

Docket No. 1819-70

United States Tax Court

58 T.C. 892; 1972 U.S. Tax Ct. LEXIS 64;

August 28, 1972, Filed

Decision will be entered for the respondent.

In 1950, the petitioner purchased all the stock of Packing, paying approximately $ 200,000 in excess of the fair market value of the underlying assets. In 1963, Packing was merged into the petitioner, and at that time, Packing had no basis for Federal income tax purposes for goodwill. In 1966, the petitioner sold its assets and…

2Cases cited8 opinions

  1. Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
  2. Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  3. B. F. Goodrich Co. v. CommissionerUnited States Tax Court · 1943
  4. Webster Investors, Inc. (Successor by Merger to Webster Investment Company, Inc) v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
  5. Howard Constr., Inc. v. CommissionerUnited States Tax Court · 1964

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