Legal Opinion

Computing & Software, Inc. v. Commissioner

United States Tax Court

Decided May 15, 1975No. Docket Nos. 4008-72, 4009-72, 8184-74PublishedCited by 68 opinions

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

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
  3. Estate of Beck v. Comm'rUnited States Tax Court · 1971
  4. Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  5. Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973

24 more not listed; retrieve them via the Exa API.

3Cited by68 opinions

  1. Ronnen v. CommissionerUnited States Tax Court · 1988
  2. VGS Corp. v. CommissionerUnited States Tax Court · 1977
  3. IT&S of Iowa, Inc. v. CommissionerUnited States Tax Court · 1991
  4. Citizens & Southern Corp. v. CommissionerUnited States Tax Court · 1988
  5. Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975

63 more not listed; retrieve them via the Exa API.

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