Warren L. Baker, Jr. And Dorris J. Baker 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.

• holding that payment under covenant not to compete is taxable as ordinary income
• finding that taxpayer owned no capital assets under a nearly identical insurance agent agreement with State Farm
• “We agree ... that (a portion of) State Farm’s payments were for a covenant not to compete.... [T]he consideration a buyer pays a seller for a covenant not to compete is taxable as ordinary income.” (citations omitted)
• “Baker owned nothing. Thus, he could sell no assets, including goodwill.”
• “Baker owned nothing. Thus, he could sell no assets, includ- ing goodwill.”
• “We agree . . . that (a portion of) State Farm’s payments were for a covenant not to compete. . . . [T]he con- sideration a buyer pays a seller for a covenant not to compete is taxable as ordinary income.” (citations omitted)

Source: CourtListener parenthetical corpus (CC0).