- 54 - without some factual predicate in this record. The record we consider, especially Mr. Dodds’s testimony, supports a contrary factual finding. Central to the structure and approach of section 1.167(a)- 1(b), Income Tax Regs., is the use of the acquiring taxpayer’s experience to determine useful life because the acquired asset will probably perform like similar property in the context of the acquirer’s business. Setting the similarity standard at an extremely high level, as contended for by respondent, could undermine the intended purpose of the regulation. There is little question that petitioner’s customer accounts were sufficiently similar to the acquired accounts to permit petitioner to use section 1.167(a)-1(b), Income Tax Regs., in determining the useful lives of the acquired accounts. We sustain the useful lives petitioner derived. Considering the parties’ experts’ approaches, we conclude and hold that petitioner has shown sufficient similarity to use its own useful life data and categorization to determine the useful lives of the acquired Rose accounts. In addition, we hold that petitioner’s approach in deriving the useful lives of the acquired Rose accounts is reasonable and appropriately reflects the useful lives for purposes of amortization. Reiterating, for the acquired cash and margin accounts, Mr. Knoblick performed an actuarial study of petitioner’s comparablePage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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