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Similarly, in these cases, petitioner seeks to amortize the right
to use borrowed money provided for in its various debt
obligations. The differential between the market rate of
interest and the contract rate of interest serves as a measure of
the economic value of that right as of January 1, 1985. Thus, we
cannot agree with respondent’s attempt to analyze petitioner’s
right to use borrowed money separately from the comparable cost
of that use. For the reasons discussed above and in Dickman v.
Commissioner, 465 U.S. 330 (1984), the right to use borrowed
money is interrelated with the corresponding interest cost of
that right, in much the same way that the right to use property
is interrelated with its corresponding rental cost.
Petitioner’s interest in its favorable financing is in many
respects analogous to a bank’s interest in its “deposit base” or
“core deposits”, which we have held to be an intangible asset
amortizable for tax purposes. “The term ‘deposit base’ describes
‘the intangible asset that arises in a purchase transaction
representing the present value of the future stream of income to
be derived from employing the purchased core deposits of a
bank.’” Newark Morning Ledger Co. v. United States, 507 U.S. at
561 n.11 (quoting Citizens & S. Corp. v. Commissioner, 91 T.C.
463, 465 (1988), affd. 919 F.2d 1492 (11th Cir. 1990)). “The
value of the deposit base rests upon the ‘ascertainable
probability that inertia will cause depositors to leave their
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