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Asset Buyer’s Substance Over Form Argument Wins $3 Million Amortization Deduction

The IRS challenged the buyer’s $3 million amortization deduction in an asset acquisition based upon the structure chosen by the parties to the transaction. The tax court however, allowed the amortization deduction based upon the economic substance of the transaction.

Posted in amortization, form over substance, substance over form, Taxation Tagged with: ,

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