- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011