Sebastopol agreement – Segregation Holding

Peco Foods should have sold assets, done new cost seg study!

By Jeff Hobbs January 25, 2012

I’m curious, would it have made sense for Peco to have created a holding company, sold the assets to the new company and then performed a new cost seg study? A new tax-basis would then be in place and qualify for a new study…any ramifications to that I’m missing? Seems to me a lot of…

Peco Foods Inc. -v- CIR (TC Memo 2012-18, January 17, 2012)

By Jeff Hobbs January 25, 2012

My initially thought is this could mean trouble to a firm doing a PPA study with cost seg “after the fact” if assets are not specifically identified in the buy-sell agreement or corresponding document. This is precisely why cost segregation professionals should be engaged at the outset, if for no other reason, to simply consult…