Computing & Software, Inc. v. Commissioner
United States Tax Court
Petitioners and their predecessors acquired the assets of three credit-reporting organizations including the voluminous files containing information used in the credit-reporting businesses. Depreciation deductions for the files were claimed based upon an allocation of a substantial part of each purchase price to the cost of the file. Held: The credit information is intangible property with a useful life of 6 years.
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Petitioners and their predecessors acquired the assets of three credit-reporting organizations including the voluminous files containing information used in the credit-reporting businesses. Depreciation deductions for the files were claimed based upon an allocation of a substantial part of each purchase price to the cost of the file. Held: The credit information is intangible property with a useful life of 6 years. Its value is separable from the goodwill and going-concern value of the acquired businesses. Held, further, amount of each purchase price allocable to the cost of the file…
1Opinion of the Court
Featherston, Judge:
Respondent determined that petitioners are liable as transferees under section 69012 for the following deficiencies in Federal income taxes in these consolidated cases:
Docket No. TYE Deficiency
4008-72 Oct. 29,1967 $33,286.00
Nov. 3,1968 211,850.00
4009-72 Dec. 31,1966 97,219.00
Aug. 30,1967 63,862.00
8184-74 Nov. 2,1969 75,778.97
Petitioners do not dispute their liabilities as transferees if the underlying income tax deficiencies are due, but they contest the determined deficiencies, raising two issues:(1) Whether certain credit information files purchased by petitioners or…
2Cases cited29 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Estate of Beck v. Comm'rUnited States Tax Court · 1971
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
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3Cited by68 opinions
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- Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
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