Tele-Media Co. v. Lindley

The first question addressed is: Does the taxpayer’s book value based upon the purchase price as allocated or the seller’s depreciated book value2 more accurately reflect the true value in money of the tangible personal property acquired?

The taxpayers contend that the seller’s lower depreciated book value is the more accurate indication of true value. They claim that the allocation of the gross purchase price to the individual-acquired assets was done primarily for Federal Income Tax purposes and was not intended to reflect their fair market value. Therefore, taxpayers argue, this allocation…