The
amortizable premium on taxable bonds acquired on or after January 1, 1958 is the excess of the individual's tax basis for determining loss on sale or exchange of the bond (determined at the start of the year) over the amount payable at maturity, or in the case of a callable bond, the earlier call date if using the earlier call date would result in a smaller
amortizable amount being allocated to the year.
This is one of the exceptions to the general rule of establishing a new
amortizable asset.
Could such taxpayers argue that an asset which is identified as an
amortizable Section 197 intangible under current law must also have been an
amortizable intangible under prior law?
A domain name that is an
amortizable intangible would be included within the IRC section 1231 definition of a capital asset, as long as the domain name is not inventory in the hands of the taxpayer.
Some banks have contended that the deposit base contributes to the production of income and is an
amortizable capital asset.
In many cases, a step-up is allocable to depreciable fixed assets or
amortizable Sec.
Are the depreciable and
amortizable lives reasonable for the asset costs being written off?
Hubbard responded that Treasury is grappling with the issue of defining the
amortizable costs.
For the first time, it is possible, in an asset acquisition for example, that goodwill is deductible for tax purposes but not
amortizable for financial accounting purposes," writes Giannini.
The IRS focus on the taxpayer's decision as the watershed for whether investigation costs are
amortizable makes it imperative for companies to carefully break out acquisition costs incurred before deciding which business to acquire.
On the other hand, the courts have consistently held that amounts allocated on an arms' length basis to a non-competition covenant are
amortizable by the payor as ordinary deductions and are ordinary income to the recipient.
2 million impairment of SRO
amortizable assets in the fourth quarter of 2010.
