Citizens & Southern Corp. v. Commissioner
United States Tax Court
During 1981 and 1982, petitioner acquired nine banks. In accordance with generally accepted accounting principles, petitioner allocated the purchase price of each bank among the acquired tangible and identifiable intangible assets, with any residual amounts being allocated to goodwill and going-concern value. Petitioner identified deposit base as a separately identifiable intangible asset.
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During 1981 and 1982, petitioner acquired nine banks. In accordance with generally accepted accounting principles, petitioner allocated the purchase price of each bank among the acquired tangible and identifiable intangible assets, with any residual amounts being allocated to goodwill and going-concern value. Petitioner identified deposit base as a separately identifiable intangible asset. Petitioner uses the term "deposit base" to describe the intangible asset that arises in a purchase transaction representing the present value of the future stream of income to be derived from employing the…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income taxes as follows:
Taxable year Deficiency
1979. $433,750
1980. 5,415,133
1981. 44,441
1982. 1,115,224
The issues for our decision are: (1) Whether petitioner is entitled to a depreciation deduction under section 167 1 with respect to the deposit base acquired in the purchase of nine banks; and (2) if so, whether petitioner is entitled to a depreciation deduction for the taxable year 1982 in an amount equal to the present value at the acquisition dates of the projected income stream attributable to the acquired core…
2Cases cited50 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Abramson v. CommissionerUnited States Tax Court · 1986
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3Cited by55 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
- Seymour Sacks Star Sacks v. Commissioner, Internal Revenue Service, Michael R. Geyser Joyce Geyser v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- IT&S of Iowa, Inc. v. CommissionerUnited States Tax Court · 1991
- FMR CORP. v. COMMISSIONERUnited States Tax Court · 1998
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