Federal Home Loan Mortgage Corporation - Page 19

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               Respondent also argues that the cases involving core                   
          deposits are distinguishable because “The core deposits in those            
          cases were acquired as part of a larger acquisition, unlike                 
          petitioner’s self-created ‘asset.’”  Respondent’s argument                  
          perhaps represents a broader criticism of petitioner’s position             
          with respect to its favorable financing because, admittedly,                
          petitioner’s favorable financing was not acquired in any purchase           
          transaction, and both parties seem to agree that petitioner has             
          not incurred any costs with respect to its favorable financing              
          such that it would have an adjusted cost basis in that alleged              
          intangible asset.                                                           
               In IT&S of Iowa, Inc. v. Commissioner, 97 T.C. 496, 507-508            
          (1991), we stated:                                                          
                    To qualify for a depreciation deduction,                          
               petitioners must show that the deposit core acquired                   
               from the * * * bank (1) had an ascertainable cost basis                
               separate and distinct from the goodwill and going-                     
               concern value of such bank, and (2) had a limited                      
               useful life, the duration of which could be ascertained                
               with reasonable accuracy.  Donrey, Inc. v. United                      
               States, 809 F.2d 534, 537 (8th Cir. 1987); Houston                     
               Chronicle Publishing Co. v. United States, 481 F.2d                    
               1240, 1250 (5th Cir. 1973); Citizens & Southern Corp.                  
               v. Commissioner, 91 T.C. at 479. * * *  [Fn. refs.                     
               omitted; emphasis added.]                                              
          See also Trustmark Corp. v. Commissioner, T.C. Memo. 1994-184               
          (“The core deposit intangible asset may be amortized upon a                 
          proper showing by petitioner of its cost basis and a reasonably             
          accurate estimate of its useful life.”).  However, the primary              







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