Computing & Software, Inc. v. Commissioner
United States Tax Court
Held: The full amount of a depreciation deduction claimed by petitioners and not disallowed in a prior year was "allowed," as that phrase is used in sec. 1016(a)(2)(B), I.R.C. 1954, with respect to a certain credit information file purchased by petitioners, and no part of such deduction was "allowed" with respect to goodwill. Petitioners' basis in the credit file must be reduced to the extent that the depreciation deduction "allowed" provided a tax benefit.
1Opinion of the Court
SUPPLEMENTAL OPINION
Featherston, Judge:
The original opinion in this case (64 T.C. 223) was filed May 15, 1975. Petitioners have raised an objection to respondent’s computations for entry of decisions pursuant to that opinion. The issue is whether, under section 1016(a)(2)(B),2 petitioners’ basis for a certain purchased credit file should be adjusted for the full amount of the depreciation allowed for 1965, prior to the period in controversy, or for only a proportionate part thereof.
On December 17,1964, Consumer Credit Clearance, Inc. (hereinafter referred to as CCC), purchased a credit…
2Cases cited7 opinions
- Computing & Software, Inc. v. CommissionerUnited States Tax Court · 1975
- Rainier Brewing Co. v. CommissionerUnited States Tax Court · 1946
- Hoboken Land & Improvement Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Pittsburgh Brewing Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1939
- Hoboken Land & Improv. Co. v. CommissionerUnited States Board of Tax Appeals · 1942
2 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
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- Texaco Inc. v. United StatesUnited States Court of Claims · 1978
- Conroe Office Bldg., Ltd. v. CommissionerUnited States Tax Court · 1991
- Woodall v. CommissionerUnited States Tax Court · 1991
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