Hall v. Commissioner
United States Tax Court
1. Held, a contract as manager of a Texas mutual assessment insurance company assigned to petitioner has no reasonably ascertainable useful life and therefore the amount paid for the assignment is not subject to depreciation or amortization. 2. Held, further: The notice of deficiency issued by respondent is a valid notice.
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1. Held, a contract as manager of a Texas mutual assessment insurance company assigned to petitioner has no reasonably ascertainable useful life and therefore the amount paid for the assignment is not subject to depreciation or amortization. 2. Held, further: The notice of deficiency issued by respondent is a valid notice. Respondent did not make a second inspection of petitioner's books of account for the year 1963 as a result of a telephone conversation between the office auditor who previously having made an office audit of petitioner's 1963 income tax return was handling a claim for…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in petitioners’ income tax for the years 1963 and 1964- in the amounts of $10,906.50 and $12,683.27, respectively.
The issues for decision are:(1) Whether the cost to one of petitioners of acquiring a management contract with a mutual assessment life insurance company is subject to depreciation or amortization and, if so, the period over which it may be amortized, and(2) Whether respondent made a second inspection of petitioners’ books for the year 1963 and, if so, does that fact cause his determination of deficiency for that year to be invalid.
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2Cases cited20 opinions
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- United States v. Charles G. Eidson, Jr.Court of Appeals for the Fifth Circuit · 1962
- Nachman v. CommissionerUnited States Tax Court · 1949
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3Cited by10 opinions
- Collins v. CommissionerUnited States Tax Court · 1974
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- Marte A. Formico and Eula J. Formico v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Formico v. CommissionerUnited States Tax Court · 1971
- Brodhead v. CommissionerUnited States Tax Court · 1979
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