The Charles Schwab Corporation and Subsidiaries - Page 35

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          Morning Ledger Co. v. United States, 507 U.S. at 566.  We agree             
          with petitioner that brokerage customers are not, per se,                   
          distinguishable from newspaper subscribers in any way that would            
          make the circumstances we consider here distinguishable from                
          those in Newark.                                                            
               C.  The Value and Useful Life of the Intangibles Petitioner            
               Acquired                                                               
               1.  In General                                                         
               Having decided that the Rose customer accounts are                     
          amortizable under section 167, we now turn to the question of the           
          values or amounts that are subject to amortization and the useful           
          lives of the assets.  On these points the parties have relied on            
          expert witnesses to provide opinion evidence based on the factual           
          record.  Generally, the parties’ experts used similar methodology           
          to arrive at the values of the Rose customer accounts.  The                 
          experts attempted to compute the net revenue stream that                    
          petitioner could expect from the Rose customer accounts.  Both              
          used petitioner’s data of customer performance in petitioner’s              
          business16 and applied the Rose revenues that were generated in             
          the year before the acquisition.                                            





               16 Respondent argues, however, that Rose’s experience would            
          be preferable and that petitioner’s experience was used because             
          Rose’s experience was not available.                                        





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Last modified: May 25, 2011