- 53 - (1969). Keeping track of prior years' events is especially necessary where, as in the instant case, the computation involves the allowance for amortization. The annual amortization deduction calculation depends on amortization allowed or allowable in prior years, and is subject to change in subsequent years if any one of the three factors on which it is based is redetermined. Moreover, the reasonableness of an allowance for amortization is to be determined in light of conditions known to exist at the end of the period for which the return is made. Sec. 1.167(b)-0(a), Income Tax Regs. The depreciation regulations, therefore, contemplate that the allowance may change as conditions change. The result we reach does no violence to the annual accounting system. Furthermore, respondent's method does not disregard the statute of limitations as it does not seek to modify amortization for prior years. We conclude that when the original amortizable basis is redetermined, as in the instant case, the unrecovered cost, as reduced by the greater of amortization previously allowed or allowable, less salvage value (if any) should be spread over the remaining useful life to arrive at the correct annual amortization allowance for subsequent years.Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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