Opinion

Citizens & Southern Corp. v. Commissioner

  • 91 T.C. 463
  • 91 T.C. No. 35
  • 1988 U.S. Tax Ct. LEXIS 139
Court
United States Tax Court
Filed
Sep 6, 1988
Status
Published
Author
Jacobs
On the bench
Goffe,Korner,Shields,Hamblen,Clapp,Swift,Wells,Whalen,Nims,Ruwe,Cohen,Korner,Hamblen,Wells,Whalen,Jacobs,Wright,Chabot,Whitaker,Gerber,Parr
Cited by
45 cases

noting that value of an acquired asset may be determined based on future income likely to be generated that by that asset discounted to present value

How later courts described this case

  • noting that value of an acquired asset may be determined based on future income likely to be generated that by that asset discounted to present value
  • noting that discounted future income stream method is one of three common approaches to asset valuation
  • noting that value of an acquired asset may be determined based on future income likely to be generated that [sic] by that asset discounted to present value
  • discounting future income is one of several techniques for valuing an asset

Written by the judges who cited it.

The opinion

JACOBS, J., concurring:

I have difficulty understanding how petitioner was able to prove that the core deposits have (1) an ascertainable cost basis separate from that of the goodwill of the acquired banks, and (2) a limited useful life, the duration of which can be determined with reasonable certainty. Nonetheless, petitioner did. Not being the trier of the facts in this case, I do not wish to, and shall not, substitute my judgment for that of the trial judge. Based on the factual predicate that the core deposits have an ascertainable cost basis separate from goodwill and that the core deposits have a determinable useful life, I am bound to concur with the result reached herein.

Parker and WRIGHT, JJ., agree with this concurring opinion.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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