The Charles Schwab Corporation and Subsidiaries - Page 54

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          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 comparable            






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