Respecting "Allocation Agreements": or Bear the Consequences

Date
2013-08-09
Authors
Harl, Neil
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Abstract

The enactment in 1990 of the detailed rules for “applicable asset acquisitions” in I.R.C. § 10601 marked a clear tightening up of the rules governing sales and purchases of assets constituting a “trade or business.”2 Recent cases, including a Court of Appeals case in July 2013,3 have clarified how such transactions should be handled.

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