Hoffman v. Commissioner

OPINION

Muedoce:, Judge:

The Commissioner in the deficiency notices stated that amortization under section 187 is not allowable with respect to the cost of the location contracts because they “are of such an indefinite character that no probable useful life can be determined.” The evidence shows the error of that reasoning.

The unrefuted testimony is that each written contract or lease was for a definite period of years stated in the contract, could be enforced at law by either party for those years but for those years only, and carried no provision for or promise of renewal. Also it is clear…