Marsh & McLennan, Inc. v. Commissioner
United States Tax Court
The petitioner, one of a large group of affiliated corporations engaged in the insurance brokerage and agency business, purchased the stock of a corporation conducting a similar business, and liquidated the acquired company, thereby acquiring all the assets of such company, including insurance expirations relating to about 2,400 accounts.
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The petitioner, one of a large group of affiliated corporations engaged in the insurance brokerage and agency business, purchased the stock of a corporation conducting a similar business, and liquidated the acquired company, thereby acquiring all the assets of such company, including insurance expirations relating to about 2,400 accounts. Held, that no part of the consideration paid for the intangible assets, including the list of expirations, is deductible as depreciation under sec. 167 of the Internal Revenue Code of 1954.
1Opinion of the Court
AtkiNS, Judge:
The respondent determined deficiencies in income tax against the petitioner for the taxable years 1961 and 1962 in the respective amounts of $1,783.22 and $7,246.27. The issue is whether the petitioner is entitled to any deduction, under section 167(a) (1) of the Internal Revenue Code of 1954, for the cost of a list of insurance customer expirations which it acquired in 1961 when it purchased an insurance brokerage business.
BINDINGS OK PACT
Some of the facts have -been stipulated and are incorporated herein by this reference.
The petitioner is a corporation organized under the…
2Cases cited8 opinions
- Michaels v. CommissionerUnited States Tax Court · 1949
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Boe v. CommissionerUnited States Tax Court · 1961
- Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Thrifticheck Service Corp. v. CommissionerUnited States Tax Court · 1960
3 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Computing & Software, Inc. v. CommissionerUnited States Tax Court · 1975
- Forward Communications Corp. v. United StatesUnited States Court of Claims · 1979
- Marsh & McLennan Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1969
- Union Bankers Ins. Co. v. CommissionerUnited States Tax Court · 1975
- Cottage Sav. Asso. v. CommissionerUnited States Tax Court · 1988
19 more not listed; retrieve them via the Exa API.