- 2 - Peter T. Stanley, for petitioner. James R. Robb and Virginia L. Hamilton, for respondent. OPINION RUWE, Judge: Respondent determined deficiencies in petitioner’s Federal income taxes as follows: Year Amount 1994 $28,996 1995 135,880 1996 110,320 After concessions,1 the issue for decision is whether petitioner must amortize noncompetition agreement payments over 15 years pursuant to section 197.2 Background The parties submitted this case fully stipulated. The stipulation of facts, stipulation of settled issues, and the attached exhibits are incorporated herein by this reference. Petitioner is a corporation that had its principal place of business in Billings, Montana, at the time it filed its petition. 1The parties filed a stipulation of settled issues in which they resolved all the issues raised in the notice of deficiency. The remaining issue related to sec. 197 was raised by petitioner in its amended petition. 2Unless 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011