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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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Last modified: May 25, 2011