- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: For the years in issue, respondent determined deficiencies in petitioners' consolidated Federal income taxes as follows: Year Deficiency 1990 $275,348 1991 494,345 1992 21,320 For 1992, petitioners claim an overpayment of $310,359. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are whether payments totaling $2,166,000 qualify as amortizable business expenses relating to a covenant not to compete and whether payments totaling $749,905 qualify as deductible salary expenses for services rendered. FINDINGS OF FACT Some of the facts are stipulated and are so found. When the petitions were filed, petitioners' principal place of business was located in Eden Prairie, Minnesota. During the years in issue, C.H. Robinson, Inc. (petitioner), was a Minnesota corporation and the parent corporation of a group of affiliated corporations that filed consolidated Federal incomePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011