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Lookup this landmark case called Indopco v. Commissioner Focus on the deductibility of merger fees with Morgan Stanley ($2,200,000 plus expenses of $7,586 & $18,000
Lookup this landmark case called Indopco v. Commissioner
- Focus on the deductibility of merger fees with Morgan Stanley ($2,200,000 plus expenses of $7,586 & $18,000 legal fees) and Debevoise ($490,000 plus expenses of $15,069). National Starch also incurred $150,962 of legal fees). What is the basic issue between the IRS and Indopco?
- How does IRC Section 162(a) apply?
- Contrast IRC Section 162 to IRC Section 263 more specifically Treas. Reg. Section 1.263(a)4(b)? What is the difference between these two sections and its application to the merger fees paid.
- Whose burden is it to prove whether IRC Section 162 applies?
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