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This is one of the exceptions to the general rule of establishing a new amortizable asset.
However, no inference is intended that any deduction should be allowed in these cases for assets that are not amortizable under present law.
732(d) was "to prevent distortions caused by section 732(c) that might inflate the basis of depreciable, depletable, or amortizable property above its fair market value," looking at whether the basis on a hypothetical pro rata liquidation would exceed the FMV appears to be a supportable starting point.
Some banks have contended that the deposit base contributes to the production of income and is an amortizable capital asset.
To qualify for amortization under IRC section 248, an organization expenditure must be directly incident to the corporation's creation, chargeable to the corporation's capital account and of a character that, if expended when creating a corporation with a limited useful life, would be amortizable over that life.
When warrants or options are part of a loan package, part of the proceeds is allocated to the warrants, creating OID, which is amortizable over the life of the loan.
338 election had not been made, Distributing would have recognized only the loss in the stock of Sub 1, if any, and Corp I would have had no new amortizable asset basis after it was spun off by Distributing.
Amortizable intangible assets-- referred to in the act as section 197 intangibles--include customer-based intangibles, supplier-based intangibles, books and records, patents, proprietary technology, copyrights, licenses, trademarks and trade names, franchise values, noncompetition agreements and goodwill-going concern values.
In restating the 2008 financial statements, the Company will increase the impairment loss associated with amortizable intangible assets by approximately $4.
197 rules, intangible assets with an ascertainable value and reasonably determinable limited useful life were amortizable.
Following the issuance of the TAM a settlement was negotiated in the case that was almost wholly satisfactory to the taxpayer: not only were the just-in-time manufacturing training expenditures involved in the case determined to be currently deductible (or amortizable over a relatively short time frame), but it was agreed that the taxpayer's ongoing expenditures for training could be currently deducted as ordinary and necessary business expenses.
Commissioner, the Tax Court concluded goodwill existed in a franchise acquisition but, because it was "franchise" goodwill rather than "business" goodwill, it was amortizable for tax purposes.