1. Home
  2. Browse Decisions
  3. F.2d
  4. 810 F.2d
  5. 810 F.2d 562 (1987)
 

PATTERSON v. C.I.R.

No. 85-1904.

810 F.2d 562 (1987)

James A. PATTERSON and Dorothy A. Patterson, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided February 2, 1987.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Tax Div., Dept. of Justice, Michael L. Paup (Lead Counsel), Roger M. Olsen, Gary R. Allen, Elaine F. Ferris (argued), Fred T. Goldberg, Jr., Chief Counsel, I.R.S., Washington, D.C., for respondent-appellant.

L.L. Leatherman, Greenbaum, Doll & McDonald, Louisville, Ky., Hiram Ely, III (Lead Counsel), argued, for petitioners-appellees.

Michael S. Horne, Covington & Burling, Washington, D.C., for amicus curiae.

Before GUY, Circuit Judge; PECK, Senior Circuit Judge; and EDGAR, District Judge.

RALPH B. GUY, Jr., Circuit Judge.

This case involves a dispute as to the amount, if any, of the consideration received for a sale of stock that is properly allocable to a covenant not to compete. The Tax Court held in favor of the taxpayer, Patterson, concluding that he had correctly allocated the entire sale price to the sale of stock. The Commissioner filed a timely appeal. For the reasons set forth below, the decision of the Tax Court is affirmed.

I.<...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases