- 52 -
Because respondent contends that there is no fair market
value to support the existence of the favorable financing
intangibles, respondent offered no view as to their useful lives.
Although Dr. Hakala disagrees that the average weighted lives
equal the remaining useful lives of the assets, Dr. Hakala
substantially agreed with the average weighted life calculations
performed by petitioner’s experts. We find that petitioner has
proven that its favorable financing intangible assets have
reasonably estimable useful lives equal to the average weighted
lives of the debt obligations from which these assets arose. We
hold that petitioner’s favorable financing intangible assets had
useful lives as follows:
Debt Average Weighted Life
G-15 5 years, 5 months
G-16 6 years, 8 months
G-17 12 years, 5 months
F-8 11 months
F-11 8 years, 11 months
F-12 2 months
F-13 12 years, 2 months
F-15 5 months
F-18 1 year, 2 months
D-2 5 years, 3 months
Z-2 34 years, 11 months
Z-3 9 years, 11 months
ND 1 year, 8 months
CD-1 4 years, 0 months
GMC A 1975 3 years, 4 months
GMC B 1975 3 years, 9 months
GMC A 1976 3 years, 10 months
GMC B 1976 5 years, 6 months
GMC A 1977 4 years, 9 months
GMC B 1977 6 years, 3 months
GMC C 1977 8 years, 2 months
GMC A 1978 8 years, 5 months
Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 NextLast modified: May 25, 2011