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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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Last modified: May 25, 2011