Colorado Nat'l Bankshares, Inc. v. Commissioner
United States Tax Court
During 1981 and 1982, petitioner acquired seven 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 "core deposits intangible" as a separately identifiable intangible asset.
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During 1981 and 1982, petitioner acquired seven 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 "core deposits intangible" as a separately identifiable intangible asset. Petitioner uses the term core deposits intangible to describe the intangible asset that represents the present value of the future stream of net income to be derived from utilizing the core…
1Opinion of the Court
COLORADO NATIONAL BANKSHARES, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Colorado Nat'l Bankshares, Inc. v. Commissioner
Docket No. 3273-88
United States Tax Court
T.C. Memo 1990-495; 1990 Tax Ct. Memo LEXIS 548; 60 T.C.M. (CCH) 771; T.C.M. (RIA) 90495;
September 17, 1990, Filed
Decision will be entered under Rule 155.
During 1981 and 1982, petitioner acquired seven 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…
2Cases cited41 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- Metropolitan Bank v. St. Louis Dispatch Co.Supreme Court of the United States · 1893
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Leahy v. CommissionerUnited States Tax Court · 1986
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