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exhibits, are actually not present in the record. Rather,
several documents purporting to be amendments to leases are
included in the record as stipulated exhibits. None of these
documents makes reference to any intangible asset. For example,
an “AMENDMENT OF LEASE”, dated November 1, 1987, purports to
amend both an equipment lease and a real property lease, but
makes no mention of any intangible asset or intangible asset
lease.
In a letter dated December 16, 1999, to respondent’s Appeals
Officer, Fred W. McMullen, (the December 16, 1999, letter)
Kaufman attempted to justify a deduction of $58,941 taken by Jack
H. Kaufman, APC. The justification for the deduction was that
“27.625% of $544,880 in debt was assumed in return for receiving
primarily client files and goodwill from the prior law firm * * *
Thus, the writeoff is supported by an allocation of the debt
assumption cost basis and the factual justification of
obsolescence in the year in question.” This justification
indicates that Kaufman transferred to Jack H. Kaufman, APC all of
the liabilities he had assumed in connection with the dissolution
of the partnership, and that Jack H. Kaufman, APC became the
owner of client files and associated goodwill that Kaufman had
acquired in connection with the dissolution of the partnership.
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Last modified: May 25, 2011