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show a value of $0 for the operating authorities.2 In addition,
petitioner's quarterly report to the Interstate Commerce
Commission for the third quarter of 1994 shows the value of
petitioner's total intangible property was $520,677 at the
beginning of 1994, and $0 at the close of the quarter.3
The question whether the pre-1995 authorities became
entirely worthless some time before or exactly at the moment the
year 1994 expired serves no purpose. As the legal life of the
operating authorities and the year 1994 each approached their
coterminous final moments, any value remaining with the operating
authorities after enactment of the FAAAA would have rapidly
approached zero. Thus, the residual value of the pre-1995
authorities during the last seconds of 1994 could have been no
more than de minimis. Accordingly, we find that petitioner's
subjective judgment of the value of its pre-1995 operating
authorities was reasonable and well founded.
Furthermore, we find that fixed and identifiable events
causing the worthlessness of the operating authorities occurred
2The financial reports also show that for the same period
during the previous year, the value of the intrastate operating
authorities was $520,677. The balance sheet of petitioner's
financial statements compiled as of January 31, 1995, also shows
a value of $0 for the operating authorities.
3Petitioner's annual report to the Interstate Commerce
Commission for the year ended Dec. 31, 1994, also shows the value
of petitioner's total intangible property was $0 at the close of
the year.
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