- 12 - Given petitioner’s inconsistent statements regarding ownership and abandonment of client files, a client list, and associated goodwill, we conclude that petitioner has not established its ownership or abandonment of any intangible asset. D. Analysis Regarding Tangible Assets Petitioner claims to have abandoned tangible assets in 1995. Respondent contends that petitioner has not established abandonment of any tangible asset and, alternatively, that petitioner has not established that any purportedly abandoned asset had an adjusted basis other than zero. Petitioner claims that Kaufman’s suspension had “devastating adverse impacts” on petitioner by adversely affecting its ability to lease office space and equipment to Jack H. Kaufman, APC. Petitioner claims to have abandoned equipment and other assets because they could no longer be used by Jack H. Kaufman, APC. Petitioner claims that equipment and other assets of no further practical use were “either destroyed, thrown out, or not used anymore.” Contrary to petitioner’s claims, there is no credible evidence that Kaufman’s suspension had devastating adverse impacts on petitioner. The entity to which petitioner leased office space and equipment, Jack H. Kaufman, APC, continued to operate throughout 1995, including the period of Kaufman’s suspension. Throughout 1995, Jack H. Kaufman, APC continued toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011