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FRONTIER CHEVROLET CO. v. C.I.R.

No. 01-71815.

329 F.3d 1131 (2003)

FRONTIER CHEVROLET COMPANY, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed May 28, 2003.

Attorney(s) appearing for the Case

Peter T. Stanley, Billings, MT, for the petitioner.

Karen D. Utiger, Tax Division, Department of Justice, Washington, DC, for the respondent.

Before: TROTT, T.G. NELSON and THOMAS, Circuit Judges.

OPINION

TROTT, Circuit Judge:

Frontier Chevrolet Company ("Frontier") appeals the tax court's decision that I.R.C. § 197 (" § 197") applied to a covenant not to compete entered into in connection with Frontier's redemption of 75% of its stock. We agree with the tax court that Frontier's redemption was an indirect acquisition of an interest in a trade or business; therefore Frontier had to amortize the covenant under § 197.

BACKGROUND...

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