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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.
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