The Charles Schwab Corporation and Subsidiaries - Page 3

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          1992 income taxes of $2,245,332, $2,797,349, $3,101,526, and                
          $827,683, respectively.  By means of amended answers, respondent            
          asserts increased income tax deficiencies of $2,644,782,                    
          $2,906,015, $3,210,191, and $936,349 for petitioner’s tax years             
          1989, 1990, 1991, and 1992, respectively.3  The issues presented            
          for our consideration are:  (1) Whether section 461(d)4                     
          proscribes certain California franchise tax deductions petitioner           
          claims; (2) whether petitioner’s acquired discount stock                    
          brokerage customer accounts may be amortized; (3) if the customer           
          accounts may be amortized, whether petitioner has established               
          their fair market value; (4) whether petitioner has shown the               
          “useful lives” of certain customer accounts for purposes of                 
          amortization; and (5) alternatively, if petitioner is                       
          unsuccessful regarding issues (2), (3), and (4), whether                    




               3 In the amended answers, respondent asserted increased                
          deficiencies attributable to the franchise tax issue and the                
          amortization of intangibles.  For 1989, respondent made no                  
          determination with respect to the franchise tax deduction                   
          petitioner claimed.  After the notice of deficiency was issued,             
          petitioner was successful in claiming the amount originally                 
          claimed in 1989 in its short year ended Dec. 31, 1988.                      
          Accordingly, respondent asserts an increased deficiency to                  
          account for petitioner’s change in position.  As to the                     
          amortization of intangibles, respondent originally determined               
          that petitioner was entitled to some amortization.  Respondent              
          changed his position in the amended answer, denying petitioner              
          any amortization and asserting increased deficiencies.                      
               4 Section references are to the Internal Revenue Code in               
          effect for the periods under consideration.  Rule references are            
          to the Tax Court Rules of Practice and Procedure.                           




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Last modified: May 25, 2011