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
Computing & Software, Inc., Successor by Merger to Computer Credit Corporation, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Computing & Software, Inc. v. Commissioner
Docket Nos. 4008-72, 4009-72, 8184-74
United States Tax Court
65 T.C. 1153; 1976 U.S. Tax Ct. LEXIS 144;
March 22, 1976, Filed
Decisions will be entered accordingly.
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…
2Cases cited8 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
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