- 15 - (Sumitomo) was one of the Walker entities' customers. Sumitomo was not a customer of petitioner before the Walker asset sale, but was after it. The Walker entities remained obligated to perform the timber contracts that petitioner did not buy from them. After the sale, the Walker entities owed more than $4.65 million to the Government for timber sales. However, the Walker entities could harvest the timber under those timber contracts and sell the logs. The Walker entities agreed to terminate their employees the day before the sale. Petitioner rehired about one-half of the employees from the Walker entities. 7. The Walkers’ Tax Court Case for Taxable Year 1988 The Commissioner proposed adjustments to the individual tax returns of D.C. and Mary Walker and Bebout for taxable year 1988. The Commissioner determined that part of the value assigned by each of them to the covenants not to compete should be reallocated to land and going-concern value. Each of them contested the adjustments by petitioning the Tax Court, but later conceded the adjustments in full. They each later filed amended returns to be consistent with the 1988 adjustments. The tax impact of the adjustments was essentially neutral.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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