- 35 - 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.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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