JHK Enterprises, Inc., A California Corporation - Page 12




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               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 to             






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