Legal Opinion

Thoms v. Commissioner

United States Tax Court

Decided May 7, 1968No. Docket No. 3426-66Published

Petitioner purchased a going, general insurance agency business including the goodwill and list of insurance expirations and all other intangible assets utilized by the seller in the operation of the business for the sum of $ 10,500. Held, the list of insurance expirations was a part of the goodwill and it had an indefinite useful life and petitioner was not entitled to an allowance for depreciation with respect to the purchase of said intangible property.

1Opinion of the Court

Alfred H. Thoms, Petitioner v. Commissioner of Internal Revenue, Respondent

Thoms v. Commissioner

Docket No. 3426-66

United States Tax Court

50 T.C. 247; 1968 U.S. Tax Ct. LEXIS 130;

May 7, 1968, Filed

Decision will be entered for the respondent.

Petitioner purchased a going, general insurance agency business including the goodwill and list of insurance expirations and all other intangible assets utilized by the seller in the operation of the business for the sum of $ 10,500. Held, the list of insurance expirations was a part of the goodwill and it had an indefinite useful life and petitioner was…

2Cases cited13 opinions

  1. In Re the Accounting of BrownNew York Court of Appeals · 1926
  2. Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
  3. Commissioner of Internal Revenue v. Maurice L. KillianCourt of Appeals for the Fifth Circuit · 1963
  4. Thrifticheck Service Corp. v. CommissionerUnited States Tax Court · 1960
  5. J. L. Cooper & Co. v. Anchor Securities Co.Washington Supreme Court · 1941

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