Before trial, the IRS had allowed a deduction for accumulated interest and loss on disposal of some acquisition assets and ITW agreed to capitalize its original $1 million damage estimate.
Thus, the Tax Court said ITW should capitalize the judgment "whether or not such obligation was fixed, contingent, or even known at the time such property was acquired.
The Tax Court's use of Webb should not lead CPAs to conclude clients should capitalize all benefit payments that take into account preacquisition service.
If a transferee pays an assumed liability, it may have to capitalize it (see Holdcroft Transportation Co.
For taxpayers the answer is probably easier when the claim is for the total destruction of a business--lost profits are a common way to capitalize the entity's value (as in Durkee and Raytheon).
By combining our core competencies with those of Cap Gemini, we believe that we are well positioned to capitalize on the confluence of economic, technological and competitive factors that are re-shaping our industry.
Shields, Co-President and Co-Chairman of EMMC, continued, "We believe that our initial western European rollout will position EMCC to capitalize on an untapped, burgeoning marketplace.
NeTpower was the first, and remains the only, solutions provider to capitalize
on a pure NT vision.
The two-tiered master reseller arrangement with BTG allows us to capitalize
on their mass-marketing expertise, offering government channel partners and customers at all levels an additional source for Informix products," Hammersla added.
Knowing this, we expect our skill position players to recognize and capitalize on a numbers advantage as soon as it appears.
We also seek to capitalize on positive numbers in the "tackle box" (Diag.
This has become is a must for us, so that come game time our offensive personnel will recognize and capitalize on anything the defense gives us.