- 2 - respondent for 1988 and 1989 are $78,759 and $245,068, respectively. All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. After an agreement between the parties,1 the issue for decision is whether petitioner is entitled to deductions for amortization of amounts paid to William Wright for a noncompetition and consulting agreement. We hold that it is to the extent set out below. FINDINGS OF FACT Some of the facts have been stipulated. The stipulated facts and the accompanying exhibits are incorporated into our findings by this reference. At the time of the filing of the petition, petitioner, Heritage Auto Center, Inc., maintained its principal place of business in Gladstone, Oregon. During the years at issue, petitioner had four shareholders: E.W. Richardson, Bob Turner, Kenneth Blewett, and Wade Zellner (Mr. Richardson, Mr. Turner, Mr. Blewett, and Mr. Zellner). At the date of trial, each one of these individuals had significant experience in the automobile dealership business. Mr. Richardson had been in the automobile dealership business for approximately 1 We leave it to the parties to include their agreed adjustments in their Rule 155 computations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011