United States Tax Court April 10, 1952, Docket No. 29685 (Burke v. Commissioner)

lead-opinion

OPINION.

Nice, Judge:

The sole issue is whether the $15,000, or any portion thereof, representing the purchase price paid for intangible assets upon the acquisition of a dry cleaning business is depreciable over the 5-year period of the covenant not to compete. Applicable provisions of the Internal Revenue Code and regulations promulgated thereunder are set forth in the margin.