PER CURIAM:
In 1961 taxpayers purchased a fire, casualty, and automobile insurance agency. The sole question raised by this appeal is whether the insurance renewals for which the parties to the purchase and sale allocated $11,775 of the price are amortizable assets. In holding for the Commissioner on motion for summary judgment, the district court answered this question in the negative.
To qualify intangible property for amortization, taxpayers had the burden...
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