United States Ninth Circuit
FRONTIER CHEVROLET CO. v. COMM'R OF INTERNAL REVENUE, 01-71815
Under Internal Revenue Code section 197, a company had to amortize a covenant not to compete made in connection with its redemption of a majority of its stock, as the redemption was an indirect acquisition of an interest in a trade or business.
Appellate Information
- Argued 11/08/2002
- Decided 05/28/2003
- Published 05/28/2003
Judges
- Before: TROTT, T.G. NELSON and THOMAS, Circuit Judges.
Court
- United States Ninth Circuit
Counsel
- For Appellant:
- Peter T. Stanley, Billings, MT, for the petitioner.
- For Appellees:
- Karen D. Utiger, Tax Division, Department of Justice, Washington, DC, for the respondent.