- 7 - For 1993, 1994, and 1995, Haas & Associates timely filed corporation income tax returns. On Haas and his wife’s 1993 joint Federal income tax return and on Haas & Associates’ 1994 and 1995 corporation income tax returns, the $190,000 relating to the covenant not to compete was amortized as an ordinary and necessary business expense deduction, and the $63,500 relating to consulting services was deducted in 1993 as an ordinary business expense as follows: Amortization Deduction Deduction for Relating to Covenant not Consulting Year to Compete Services Haas’ Joint Income Tax Return 1993 $58,056 $63,500 Haas & Associates’ Corporation Income Tax Return 1994 63,333 -– 1995 63,333 -– On audit, respondent disallowed the above deductions relating to the covenant not to compete and to the consulting services. In the alternative only, if these deductions are not allowed, petitioners claim that the $151,000 relating to thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011