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Alexa Olson, A Minor, Kimberly Olson, Legal Conservator--docket
No. 16945-95
Year Deficiency
1990 $3,195
Bruce A. and Kimberly A. Olson--docket No. 16946-95
Year Deficiency
1990 $55,679
Respondent conceded the accuracy-related penalty in docket
No. 16787-95, and petitioner in docket No. 5220-95 has not
argued, and thus conceded, the FSAA adjustment decreasing State
Supply's sales promotion deduction for 1989. The sole issue for
decision therefore is whether State Supply may amortize $2.5
million, or some lesser amount, for covenants not to compete.
FINDINGS OF FACT
State Supply was incorporated under the laws of the State of
Oklahoma on October 14, 1963. At the time of the filing of its
petition, State Supply's principal place of business was Tulsa,
Oklahoma. During the taxable year 1989, State Supply was a
corporation which elected to be taxed for Federal income tax
purposes under the provisions of Subchapter S of the Internal
Revenue Code of 1986, as amended. For the taxable year 1989,
State Supply is controlled by the TEFRA notice and assessment
procedures provided by sections 6241-6245. Douglas J. Von Allmen
was the tax matters person for 1989. During the taxable year
1989, the shareholders of State Supply were Douglas J. and Linda
L. Von Allmen, Bruce A. and Kimberly A. Olson, Charles B. and
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