9 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 seeksPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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