Discount Brokerage Customer Accounts-Stock Purchase
Treated as Asset Acquisition-Valuation and Useful Life of
Customer Accounts.-Where on Mar. 31, 1989, petitioner corpora-
tion X purchased all outstanding shares of discount stock brokerage
Y and elected under sec. 338(g) and (h)(10) to assign acquisition
price to acquired assets with benefit of stepped-up basis in acquired
assets; X valued customer accounts acquired from Y and amortized
them as intangible assets under sec. 167; and Commissioner con-
tended X's acquired brokerage customer accounts were not amortiz-
able, were overvalued, or had indeterminable useful lives in some
instances, Court determined discount brokerage customer accounts
were amortizable, since they were distinct from goodwill and had
limited useful life (Newark Morning Ledger Co. v. United States,
507 U.S. 546, followed); and X properly valued and calculated use-
ful life of acquired customer accounts by drawing on X's useful life