Legal Opinion

AMDAHL CORP. v. COMMISSIONER

United States Tax Court

Decided June 17, 1997No. Docket No. 2944-95Published

P paid relocation expenses of its employees and provided financial assistance in connection with the sale of their residences. P contracted with relocation service companies (RSC) to manage the sale of the employees' residences. The RSC paid the employees their equity in their homes and paid the costs of maintaining the residences, including mortgage and property tax expenses, until third parties purchased the residences.

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P paid relocation expenses of its employees and provided financial assistance in connection with the sale of their residences. P contracted with relocation service companies (RSC) to manage the sale of the employees' residences. The RSC paid the employees their equity in their homes and paid the costs of maintaining the residences, including mortgage and property tax expenses, until third parties purchased the residences. P reimbursed the RSC for its expenses and paid the RSC a fee. The relocating employees retained legal title to the residences. R disallowed a deduction to P for certain…

1Opinion of the Court

AMDAHL CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

AMDAHL CORP. v. COMMISSIONER

Docket No. 2944-95

United States Tax Court

108 T.C. 507; 1997 U.S. Tax Ct. LEXIS 33; 108 T.C. No. 24;

June 17, 1997, Filed

Decision will be entered under Rule 155.

P paid relocation expenses of its employees and provided financial assistance in connection with the sale of their residences. P contracted with relocation service companies (RSC) to manage the sale of the employees' residences. The RSC paid the employees their equity in their homes and paid the costs…

2Cases cited19 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  3. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  4. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  5. Sanford v. CommissionerUnited States Tax Court · 1968

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