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fact, this Court held that checking and savings accounts were
similar to NOW accounts for purposes of section 1.167(a)-1(b),
Income Tax Regs. We have little difficulty using the same
reasoning here; i.e., discount brokerage customers are
generically similar enough for purposes of the regulation to
allow petitioner to use its own data to determine the useful
lives of the acquired customer accounts.
Respondent also relies on the Colo. Natl. Bankshares case
with respect to the method used to analyze the useful life of
acquired bank deposits. Respondent points out that the Court
relied on the historical data on deposits where it was available.
Where the data was missing, however, the life of the acquired
deposits was estimated on the basis of the historical data of
other banks. The object lesson of that rationale, however, is
that historical data of the acquired asset is not essential to
determining similarity. Indeed, the regulation itself permits
industry experience as a substitute.
Respondent also argues that Colo. Natl. Bankshares shows
that deposits at different banks “behaved” differently and, on
the basis of that fact, respondent contends we should expect that
Rose’s discount brokerage accounts would not necessarily be
similar to those of petitioner. We cannot rely on such analogies
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