Personal Goodwill Revisited

Personal Goodwill Revisited

In Darrell Arne’s recent newsletter dealing with personal goodwill, Darrell notes that a case tried over 12 years ago is still being cited in recent personal goodwill cases.  He provides a summary of this case, Martin Ice Cream Co. v. Commissioner 110 TC 189 (March 17, 1998), and then goes on to summarize four more recent tax cases that challenged PGW allocations.  Darrell closes his newsletter with five lessons from the court, including what industry makes it harder to argue personal goodwill and what type of agreements support the allocation to personal goodwill. Recommended reading!