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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 income
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