1. Home
  2. Browse Decisions
  3. F.3d
  4. 652 F.3d
  5. 652 F.3d 122 (2011)
 

RECOVERY GROUP, INC. v. C.I.R.

No. 10-1886.

652 F.3d 122 (2011)

RECOVERY GROUP, INC., et al., Petitioners, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

Decided July 26, 2011.

Attorney(s) appearing for the Case

Peter L. Banis, with whom Banis, O'Sullivan & McMahon, LLP, was on brief for petitioners.

Damon W. Taaffe, Attorney, Tax Division, Department of Justice, with whom John A. DiCicco, Acting Assistant Attorney General, and Thomas J. Clark, Attorney, were on brief for respondent.

Before TORRUELLA, Circuit Judge, SOUTER, Associate Justice, and BOUDIN, Circuit Judge.

TORRUELLA, Circuit Judge.

The present appeal requires us to determine whether 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 considered a "section 197 intangible," within the meaning of I.R.C. § 197(d)(1)(E), regardless of whether the portion of stock acquired constitutes at least a "substantial portion" of such corporation's total stock. For the...

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