Valuation of Intangible Assets: Section 338



Intangible Asset Corporate Taxation Transfer Price Patient Relationship Replacement Cost 
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  1. 4.
    Customer-based assets are defined as “those intangible assets which are closely associated with continuing the customer relationships developed by the acquired business.” See page 1. ISP Coordinated Issue Paper: Customer-Based Intangibles. Internal Revenue Service, January 1990.Google Scholar
  2. 6.
    For example, the Appeals court in Newark Morning Ledger Co. v. U.S. noted that, “if the [paid] subscribers [the customer-based intangible at issue] were contractually obligated to continue subscribing for some period of time, Morning Ledger [the taxpayer seeking to amortize the ‘paid subscriber’ intangible] clearly would be permitted to depreciate the value of those contracts over that time period. In such an event, continued patronage would not be a mere ‘expectation,’ but a contractual right....”Google Scholar

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© Kluwer Academic Publishers 2004

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