C.H. Robinson, Inc. and Subsidiaries - Page 2

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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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