James A. Patterson and Dorothy A. Patterson v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• commissioner’s interest in tax treatment of noncompete limited to ensuring that transaction is reported consistently to prevent both parties from claiming treatment that produces least tax revenue
• “The Danielson rule can only be meaningfully applied in those cases where a specific amount has been mutually allocated to the covenant as expressed in the contract.”
• “The Danielson rule can only be meaningfully applied in those cases where a specific amount has been mutually allocated to the covenant as expressed in the contract.” (emphasis added)
• although commissioner should be slow to go beyond values assigned to noncompetition agreement by taxpayers, substance must prevail over form especially when there is reason to suspect collusion or overreaching
• “The Danielson rule can only be meaningfully applied in those cases where a specific amount has been mutually allocated to the covenant as expressed in the contract.” (emphasis added)

Source: CourtListener parenthetical corpus (CC0).