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Intangibles. If an intangible asset is known from
experience or other factors to be of use in the
business or in the production of income for only
a limited period, the length of which can be
estimated with reasonable accuracy, such an
intangible asset may be the subject of a
depreciation allowance. Examples are patents and
copyrights. An intangible asset, the useful life
of which is not limited, is not subject to the
allowance for depreciation. No allowance will be
permitted merely because, in the unsupported
opinion of the taxpayer, the intangible asset has
a limited useful life. No deduction for
depreciation is allowable with respect to
goodwill * * *
Thus, generally, if an intangible asset is shown to have an
ascertainable value and a limited useful life which can be
determined with reasonable accuracy, the depreciation
allowance may be utilized. The "significant question for
purposes of depreciation is * * * whether the asset is
capable of being valued and whether that value diminishes
over time." Newark Morning Ledger Co. v. United States,
507 U.S. 546, 566 (1993). Covenants not to compete and
client lists may constitute amortizable intangible assets.
See id.; Balthrope v. Commissioner, 356 F.2d 28, 31 (5th
Cir. 1966); O'Dell & Co. v. Commissioner, 61 T.C. 461, 466
(1974); Wager v. Commissioner, 52 T.C. 416, 419 (1969);
Levinson v. Commissioner, 45 T.C. 380, 389 (1966). In
passing, we note that for intangibles acquired after
August 10, 1993, section 197 allows a taxpayer to amortize
the adjusted basis of the intangibles ratably over a 15-
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