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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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