Valuation of Acquiree’s Customer Accounts Using Acquirer’s Data Upheld

Business Valuation UpdateVol. 10 No. 6
Legal and Court Case Update
June 2004
6211 Security Brokers, Dealers, and Flotation Companies
523120 Securities Brokerage
federal taxation
income tax

The Charles Schwab Corporation v. Commissioner
122 T.C. No. 10, 2004 U.S. Tax Ct. LEXIS 10
March 9, 2004
Federal Court
United States Tax Court
Erin M. Collins, Glenn A. Smith, Laurence J. Bardoff, Rebecca T. Hill
J. Henry Knoblick (for Charles Schwab) <br> Lee B. Shepard (for IRS)


Charles Schwab amortized the customer accounts that it had acquired through a merger. The Commissioner challenged the amortization and this suit followed.

See Also

The Charles Schwab Corporation v. Commissioner

Petitoner demonstrates it could determine the useful life of customer accounts it acquired after purchasing "Rose & Co." and therefore amortize them.