Deseret Management Corporation v. United States

Tax refund claim; Trial; Exchange of radio stations; Like-kind exchange — section 1031 of the Code; Goodwill — qualitative and quantitative aspects; Significant goodwill not transferred in exchange of radio stations; Class lives of depreciable property — sections 167 and 168 of the Code; Air conditioning equipment reclassified; Other assets received proper class lives; Refund process- established.

OPINION

ALLEGRA, Judge:

This tax refund case is before the court following trial in Washington, D.C. There are two distinct issues presented in this case. The first involves the tax treatment of a swap…