- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION HAINES, Judge: Respondent determined a deficiency in petitioners R. William Becker and Mary Ann Becker’s Federal income tax of $615,681 for their 1996 taxable year.1 Respondent determined the following deficiencies in petitioner Becker Holding Corporation’s Federal income tax: Tax Year Ended Deficiency September 30, 1993 $1,566,852 September 30, 1994 86,973 September 30, 1995 245,644 After concessions,2 the sole issue for decision is what portion, if any, of the consideration paid by Becker Holding Corporation (BHC) to R. William Becker (William Becker) in redemption of William Becker’s stock in BHC should be allocated to a covenant not to compete. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of fact and the attached exhibits are incorporated herein by this reference. At the time the petitions were filed, William and Mary Ann Becker resided in Vero Beach, 1 Amounts are rounded to the nearest dollar. 2 In a Stipulation of Settled Issues, filed Jan. 9, 2006, in docket No. 6400-03, petitioner Becker Holding Corporation and Subsidiaries (BHC) and respondent agreed to various adjustments to BHC’s Federal income tax liability for the tax years ended Sept. 30, 1993, 1994, and 1995.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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