| 1 | 11/7/2003 | BVLaw |
In the Matter of Colorado Interstate Gas Company
At issue is the capitalization rate, the inclusion of certain intangibles and the method for allocation (original cost vs. net book or rate base).
Supreme Court Kansas US, Action: State Taxation (incl. Ad Valorem)
Full Text of Court Cases (11,608 words)
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| 2 | 3/15/2002 | BVLaw |
Belleville Toyota, Inc. v. Toyota Motor Sales, U.S.A., Inc.
The Illinois Supreme Court affirmed a damage award for violation of the Motor Vehicle Franchise Act. On appeal, Toyota argued that the lost profits calculations were speculative, because eight different potential damage awards were submitted by the jury...
Supreme Court Illinois US, Action: Contract
Full Text of Court Cases (15,208 words)
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| 3 | 8/20/1999 | BVLaw |
Pan Asia Venture Capital Corp. v. Hearst Corp., et al.
The California Court of Appeals, First District, Division Four considered two approaches - the revenue allocation approach and the physical allocation approach - for calculating the cost of newspaper advertising space in this Unfair Trade Practices Act ma...
Court of Appeals California US, Action: Intellectual Property
Full Text of Court Cases (10,292 words)
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| 4 | 12/13/2006 | BVLaw |
Becker v. Commissioner of Internal Revenue
Tax Court declines to allocate a portion of stock purchase to a non-compete, when documents unambiguously allocate the entire price to the stock.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (7,546 words)
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| 5 | 12/30/1998 | BVLaw |
DHL Corporation and Subsidiaries v. Commissioner of Internal Revenue
At issue are deficiencies in income tax for petitioner.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (40,041 words)
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| 6 | 12/10/2009 | BVLaw |
Veritas Software Corp. v. Commissioner
IRS loses billion-dollar transfer pricing case based on expert’s wrong determinations of cost of capital and more.
United States Tax Court Federal Circuit US, Action: Federal Taxation
Full Text of Court Cases (15,230 words)
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| 7 | 8/30/2005 | BVLaw |
Xilinx Inc. v. Comm’r
Tax Court holds that IRS inclusion of stock-based compensation in the cost pool was "arbitrary and capricious," because parties can make an arms-length arrangement not to share the spread or grant date value.
United States Tax Court Federal Circuit US, Action: Federal Taxation
Full Text of Court Cases (9,105 words)
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| 8 | 1/29/1997 | BVLaw |
International Multifoods v. Commissioner
At issue is the whether the amounts allocated to goodwill and a covenant not to compete with this business sale constitute U.S. source income or foreign source income for the purpose of allowing a foreign tax credit carryback.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (8,622 words)
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| 9 | 1/23/1996 | BVLaw |
Heritage Auto Center v. Commissioner
At issue is whether petitioner is entitled to deductions for amortization of amounts paid to William Wright for a noncompetition and consulting agreement.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (5,477 words)
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| 10 | 2/19/1991 | BVLaw |
Sundstrand Corporation and Subsidiaries, Petitioner v. Commissioner of Internal Revenue
During 1977 and 1978, petitioner and its subsidiaries manufactured and sold numerous products, including the constant speed drive (CSD), an extremely complex avionic device used to drive an airplane engine's generator at a constant speed regardless of...
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (67,475 words)
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| 11 | 5/14/2003 | BVLaw |
Estate of McCord v. Commissioner
Business Valuation and Taxes: Procedure, Law and Perspective...
United States Tax Court US, Action: Estate and Gift Taxation
Full Text of Court Cases (27,115 words)
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| 12 | 8/6/2008 | BVLaw |
Fisher v. U.S.
Federal Claims Court rules against long-standing IRS position that stock in insurance company demutualization has a cost-basis of zero value.
United States Court of Federal Claims Federal Circuit US, Action: Federal Taxation
Full Text of Court Cases (13,641 words)
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| 13 | 4/11/2003 | BVLaw |
Indeck Energy Services, Inc. v. Commissioner
Issues are whether part of settlement payment constitutes interest deductible by Indeck and recognizable as ordinary income by petitioners, and whether penalties apply.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (13,471 words)
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| 14 | 3/26/2008 | BVLaw |
Estate of Mirowski v. Commissioner
Tax court upholds near-death transfers of family limited partnership.
United States Tax Court Federal Circuit US, Action: Estate and Gift Taxation
Full Text of Court Cases (21,763 words)
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| 15 | 1/28/2000 | BVLaw |
Beaver County v. WilTel, Inc.
Issue was the proper method of valuing WilTel, Inc. for property tax purposes.
Supreme Court Utah US, Action: State Taxation (incl. Ad Valorem)
Full Text of Court Cases (6,192 words)
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| 16 | 5/28/2003 | BVLaw |
Eighth Circuit reallocates value of covenant not to compete to intangible assets using a nine-factor test
The parties to the sale of a beer distributorship allocated $1 million to the covenant not to compete and assigned no value to the company's intangible assets. The IRS challenged the allocat...
United States Court of Appeals
Court Case Digests (708 words)
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| 16 | 11/12/1996 | BVLaw |
Pabst Brewing v. Commissioner
At issue is the fair market value of certain assets that petitioner transferred to G. Heileman Brewing Co. during the taxable period ended March 19, 1983.
United States Tax Court US, Action: Federal Taxation
Full Text of Court Cases (9,742 words)
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| 18 | 3/15/2002 | BVLaw |
Damages Awarded for Violation of the Motor Vehicle Franchise Act
The Illinois Supreme Court affirmed a damage award for violation of the Motor Vehicle Franchise Act. On appeal, Toyota argued that the lost profits calculations were speculative, because eight different potential damage awards were submitted by the jury...
Court Case Digests (1,043 words)
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| 19 | 3/30/1998 | BVLaw |
Five Star Concrete, LLC v. Klink, Inc.
Issue is whether dissociating member of LLC had the legal right to receive a cash distribution equal to its tax allocation, and whether valuation method resulted in FMV determination.
Court of Appeals Indiana US, Action: Miscellaneous
Full Text of Court Cases (2,329 words)
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| 20 | 2/28/2007 | BVLaw |
Allocation of Stock Purchase Price to Non-Compete Must be Clear, Unambiguous
Tax Court declines to allocate a portion of stock purchase to a non-compete, when documents unambiguously allocate the entire price to the stock.
United States Tax Court
Court Case Digests (714 words)
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