United States First Circuit
Recovery Group, Inc. v. Commissioner of Internal Revenue, 10-1886
In a tax dispute arising from the redemption of certain shares belonging to plaintiff's former shareholder, judgment of the tax court concerning respondent's notices of tax deficiencies is affirmed where a covenant not to compete, entered into in connection with the acquisition of a portion of the stock of a corporation that is engaged in a trade or business, is an amortizable intangible within the meaning of I.R.C. section 197(d)(1)(E).
Appellate Information
- Decided 07/26/2011
- Published 07/26/2011
Judges
- TORRUELLA
Court
- United States First Circuit
Counsel
- For Appellant:
- Peter L. Banis, Damon W. Taaffe