INDOPCO, Inc. v. Commissioner
United States Supreme Court
503 U.S. 79 (1992)
- Written by Sara Rhee, JD
Facts
INDOPCO, Inc. (INDOPCO) (plaintiff), formerly known as National Starch and Chemical Corporation, was a Delaware corporation. Unilever United States Inc. (Unilever), one of INDOPCO’s suppliers, sought to acquire INDOPCO in a friendly takeover. INDOPCO agreed and accordingly hired investment bankers and attorneys to handle the transaction. INDOPCO incurred an investment banker fee of $2,225,586, legal fees of $505,069, and miscellaneous fees relating to the acquisition of $150,962. On its federal tax return for that year, INDOPCO claimed a business expense deduction for the investment banker fees only. The Commissioner (defendant) determined that INDOPCO could not deduct the expenses. INDOPCO petitioned the Tax Court and claimed a deduction for the investment banker fees in addition to the legal and miscellaneous fees. The Tax Court held that all the expenditures were capital investments and therefore non-deductible under § 162 of the Internal Revenue Code. The Court of Appeals affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Blackmun, J.)
What to do next…
Here's why 811,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
