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We also cannot distinguish the cases involving deposit base
for the reason that those cases involved an acquisition of
deposit base in conjunction with a larger acquisition of assets
of a company. We might agree that, as a practical matter, a
debtor’s position with respect to its favorable financing would
not be transferred, except as a part of a larger acquisition of a
company or property. However, this is not, in our view,
determinative of the question of whether there exists an
amortizable asset of value. Indeed, in Citizens & S. Corp. v.
Commissioner, 91 T.C. at 492-493, we stated:
Petitioner argues in the alternative that separate
sales are not required to establish that an asset has a
determinable value separate from goodwill. In a case
involving the purchase of a professional football team,
the Fifth Circuit in Laird v. United States, * * * [556
F.2d 1224 (5th Cir. 1977)], held:
“the [players’] contracts had an ascertainable
value separate and distinct from the value of the
franchise (which thus has the same significance in
this case as goodwill had in Houston Chronicle) *
* * the valuation figure set by the district judge
for the players’ contracts was supported by the
evidence, and reflected their own particular
value, notwithstanding the fact that they were
acquired in a bundle of rights and intangibles. *
* *
* * * * * * *
“It does not matter for purposes of
amortization if individual assets only have
economic significance in the context of an
integrated transaction involving the sale of a
number of assets. [556 F.2d at 1233-1234. Fn.
refs. omitted.]”
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