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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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