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THOMS v. COMMISSIONER

Docket No. 3426-66.

50 T.C. 247 (1968)

ALFRED H. THOMS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 7, 1968.

Attorney(s) appearing for the Case

Michael J. Mehr, for the petitioner.

Ralph F. Keister, for the respondent.

MULRONEY, Judge:

Respondent determined deficiencies in petitioner's income tax for the years 1961 and 1962 in the respective amounts of $698.49 and $4,275.70.

The issue is whether the insurance customer list, or as we will sometimes call it, the list of expirations, which was included in petitioner's purchase of a going insurance business can be the subject of a depreciation allowance under section 167(a)(1), I.R.C. 1954.1

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