- 24 - 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 toPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011