Legal Opinion
Commissioner v. Danielson
Court of Appeals for the Third Circuit
Decided May 2, 1967No. Nos. 15826-15829PublishedCited by 272 opinions
1Opinion of the Court
OPINION OF THE COURT
SEITZ, Circuit Judge.
This is the decision on various petitions of the Commissioner of Internal Revenue to review a decision of the Tax Court of the United States determining the tax treatment of certain payments-which were recited in certain covenants-not to compete to be the consideration for such covenants. That court decided that the amount explicitly allocated as-payment for each selling stockholder’s covenant not to compete should not, for tax purposes, be treated as having been received for such covenants. The correctness of this ruling under the particular facts is…
2Cases cited30 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- United States v. General Motors Corp.Supreme Court of the United States · 1966
- Bartels v. BirminghamSupreme Court of the United States · 1947
25 more not listed; retrieve them via the Exa API.
3Cited by272 opinions
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Schmitz v. CommissionerUnited States Tax Court · 1968
- Albert H. And Doris G. Throndson v. Commissioner of Internal Revenue, Albert H. And Doris G. Throndson v. Commissioner of Internal Revenue, J. Leonard Schmitz and Alice Schmitz v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Brountas v. CommissionerUnited States Tax Court · 1979
- Coleman v. CommissionerUnited States Tax Court · 1986
267 more not listed; retrieve them via the Exa API.