Bill L. and Patricia M. Spencer - Page 53

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          (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.                                








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