Frontier Chevrolet Co. - Page 2




                                        - 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.                                                                  




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