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.
Harl, Neil E.
"Respecting "Allocation Agreements": or Bear the Consequences,"
Agricultural Law Digest: Vol. 24
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol24/iss16/1