Vena Marilyn Wofford - Page 9

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          sales manager, petitioner believed the typical turnover rate to              
          be 5 to 10 years.  Petitioner determined the useful life of the              
          customer lists she had acquired in 1988 by determining how many              
          customers contained thereon remained active as of the end of                 
          1992.  She found that 85 to 95 percent of the customers were no              
          longer purchasing from her at that time, and, from this, she                 
          estimated the useful life of the bases to be 7 years.                        
               Petitioner acted as a Safeguard distributor from February 1,            
          1988, and throughout the years in issue, carrying on this                    
          business under the name of Prestonwood Business Forms.  Other                
          than the salary which petitioner received from Safeguard for the             
          month of January 1988, petitioner's only other source of gross               
          income was derived from rental real estate property that she                 
          operated at a loss during the taxable years in issue.  At the                
          time of trial, petitioner continued to be engaged in business as             
          a Safeguard distributor.                                                     
               Petitioner claimed deductions for amortization related to               
          the customer lists based on a cost basis of $588,020 and a useful            
          life of 7 years.  Petitioner filed her income tax returns for the            
          taxable years 1988, 1989, 1990, and 1991 in 1993.  On Schedule C,            
          Profit or Loss from Business or Profession, of her Federal income            
          tax return filed for the taxable year 1988, petitioner claimed               
          amortization deductions in the amount of $77,003.  Petitioner                
          claimed amortization deductions in the amount of $84,003 on                  
          Schedule C of her return filed for 1989.  Petitioner seeks                   




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