108 T.C. No. 24 UNITED STATES TAX COURT AMDAHL CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2944-95. Filed June 17, 1997. P paid relocation expenses of its employees and provided financial assistance in connection with the sale of their residences. P contracted with relocation service companies (RSC) to manage the sale of the employees' residences. The RSC paid the employees their equity in their homes and paid the costs of maintaining the residences, including mortgage and property tax expenses, until third parties purchased the residences. P reimbursed the RSC for its expenses and paid the RSC a fee. The relocating employees retained legal title to the residences. R disallowed a deduction to P for certain payments to the RSC against ordinary income and treated the payments as a capital loss. R argues that P acquired equitable ownership of the residences. Held: Neither P nor the RSC acquired legal or equitable ownership of the residences for FederalPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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