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C. I. R. v. DANIELSON

Nos. 15826-15829.

378 F.2d 771 (1967)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Carl L. DANIELSON and Pauline S. Danielson, Respondents, COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Helen P. SHERMAN, Respondent, COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. ESTATE of Jacob F. SCHAFFNER, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Respondents, COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. Hugh E. McLENNAN and Katherine McLennan, Respondents.

United States Court of Appeals Third Circuit.

Reargued December 20, 1966.

Decided May 2, 1967.

Attorney(s) appearing for the Case

Stephen H. Paley, Dept. of Justice, Tax Division, Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Attys., Dept. of Justice, Washington, D. C., on the brief), for petitioner.

Sidney B. Gambill, Pittsburgh, Pa. (Charles C. Cohen, Reed, Smith, Shaw & McClay, Linn V. Phillips Jr., Neely, Stockdale & Phillips, Pittsburgh, Pa., on the brief), for respondents.

Before STALEY, Chief Judge, and McLAUGHLIN, KALODNER, HASTIE, SMITH, FREEDMAN and SEITZ, Circuit Judges.

OPINION OF THE COURT

SEITZ, Circuit Judge.

This is the decision on various petitions of the Commissioner of Internal Revenue to review a decision of the Tax Court of the United States determining the tax treatment of certain payments which were recited in certain covenants not to compete to be the consideration for such covenants. That court decided that the amount explicitly allocated as payment for each selling stockholder's covenant not to compete should...

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