Securities-Intermountain, Inc. v. United States

JAMES M. CARTER, Circuit Judge:

The United States appeals from the decision of the district court which allowed recovery to Securities-Inter-mountain (Securities), the plaintiff below, for federal income taxes paid for the years 1964, 1965, and 1966. The appeal raises the issue of whether a mortgage portfolio purchased by Securities is an asset which can be fully depreciated under § 167(a), Int.Rev.Code of 1954. We affirm, based on the finding of the district court that no part of the price paid constituted payment for property, tangible or intangible, other than the mortgage portfolio.

The…