The Charles Schwab Corporation and Subsidiaries - Page 56

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               In summary, we sustain the values and useful lives                     
          petitioner advocates.28                                                     
               To account for concessions of the parties and to reflect the           
          foregoing,                                                                  
                                             Decisions will be entered                
                                        under Rule 155.                               





















               27(...continued)                                                       
          customer accounts of $12,951,000, which was adjusted to                     
          $12,587,000 for purposes of allocating petitioner’s acquisition             
          cost to the tax bases of the assets under petitioner’s sec. 338             
          election.                                                                   
               28 Because we have sustained petitioner’s position with                
          respect to the values and useful lives of the acquired intangible           
          assets, it is unnecessary to consider petitioner’s argument that            
          it is entitled to an abandonment loss with respect to the assets            
          it disregarded in connection with the acquisition of Rose.                  

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