IT&S of Iowa, Inc. v. Commissioner
United States Tax Court
P, a State bank, acquired the assets and liabilities of another State bank, W. P allocated a portion of the purchase price to a core deposit intangible asset, based on its calculation of the cost savings realized by using the core deposits, rather than an alternative funding source, to fund P's assets. After allocation of the purchase price among specific assets, including the core deposit intangible, P allocated the residual amount of the purchase price to goodwill.
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P, a State bank, acquired the assets and liabilities of another State bank, W. P allocated a portion of the purchase price to a core deposit intangible asset, based on its calculation of the cost savings realized by using the core deposits, rather than an alternative funding source, to fund P's assets. After allocation of the purchase price among specific assets, including the core deposit intangible, P allocated the residual amount of the purchase price to goodwill. P claimed amortization deductions on account of the core deposit intangible asset based on the present value of the cost…
1Opinion of the Court
IT&S OF IOWA, INC., and IOWA TRUST AND SAVINGS BANK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
IT&S of Iowa, Inc. v. Commissioner
Docket No. 10741-88
United States Tax Court
97 T.C. 496; 1991 U.S. Tax Ct. LEXIS 96; 97 T.C. No. 34;
November 12, 1991, Filed
Decision will be entered under Rule 155.
P, a State bank, acquired the assets and liabilities of another State bank, W. P allocated a portion of the purchase price to a core deposit intangible asset, based on its calculation of the cost savings realized by using the core deposits, rather than an alternative funding source, to fund…
2Cases cited21 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
- Parker v. CommissionerUnited States Tax Court · 1986
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
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