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SPC-SC
Termite contracts:
Corrected amortizable basis $334,406
Less: previously allowed amortization (108,031)
Adjusted basis 226,375
Divided by remaining useful life 11.417
Allowed amortization deduction 19,828
Pest control contracts:
Corrected amortizable basis $660,136
Less: previously allowed amortization (324,092)
Adjusted basis 336,044
Divided by remaining useful life 6.417
Allowed amortization deduction 52,368
SPC-FL
Termite contracts:
Corrected amortizable basis $112,250
Less: previously allowed amortization (3,668)
Adjusted basis 108,582
Divided by remaining useful life 14.58
Allowed amortization deduction 7,447
Pest control contracts:
Corrected amortizable basis $824,415
Less: previously allowed amortization (125,576)
Adjusted basis 698,839
Divided by remaining useful life 9.58
Allowed amortization deduction 72,948
OPINION
In the notice of deficiency, respondent determined that the
Spencers were not entitled to take into account in determining
their taxable income for taxable years 1990, 1991, and 1992, Mr.
Spencer's pro rata share of ordinary loss from SPC-SC for such
years because Mr. Spencer's claimed losses exceeded his basis in
his stock in SPC-SC and indebtedness owed to him by SPC-SC.
Respondent also determined that the Spencers were not entitled to
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