- 30 - Mortgage Corp. v. Commissioner, 121 T.C. at 272. We also concluded that the core deposit cases, which use cost savings to measure value, “support petitioner’s position that favorable financing is an intangible asset subject to amortization.” Id. at 264. Rather than addressing the valuation issue presently before the Court, respondent’s argument seems to challenge our prior holdings. 2. Realization of Value Respondent argues that the favorable financing intangible assets do not have a fair market value and that any value is hypothetical because petitioner could not transfer favorable financing to a willing buyer. We might agree that petitioner’s favorable financing could not be transferred by itself. However, we have previously rejected respondent’s argument that favorable financing could not be valued because it could not be transferred except as part of a larger acquisition. Obviously, intangibles such as core deposits or deposit base13 might have economic 13 The term “deposit base” represents the present value of the future stream of income to be derived from employing the core deposits of a bank. See Fed. Home Loan Mortgage Corp. v. Commissioner, 121 T.C. at 262. “Core deposits are a relatively low-cost source of funds, reasonably stable over time, and relatively insensitive to interest rate changes.” Citizens & S. Corp. & Subs. v. Commissioner, 91 T.C. 463, 465 (1988). In First Chi. Corp. v. Commissioner, T.C. Memo. 1994-300, we defined core deposits as follows: Core deposits can be an essential part of a commercial bank when they represent a low cost and (continued...)Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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