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ITHACA INDUSTRIES, INC. v. COMMISSIONER

Docket No. 7076-89.

97 T.C. 253 (1991)

ITHACA INDUSTRIES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 12, 1991.

Attorney(s) appearing for the Case

David M. Ivey, Patrick G. Jones, Alison M. Drummond, William A. Turner, Phillip A. Bradley, and Kendall L. Houghton, for the petitioner.

Gary F. Walker, David R. Reid, and Albert L. Sandlin, Jr., for the respondent.

SCOTT, Judge:

Respondent determined deficiencies in petitioner's corporate income tax for its fiscal years ending February 3, 1984, and February 1, 1985, in the amounts of $404,290 and $572,775, respectively. The issues for decision are: (1) Whether an assembled work force is an intangible asset distinct from goodwill or going-concern value with an ascertainable useful life over which the value of the asset may be amortizable...

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