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367(a) and (d) with respect to foreign goodwill and going concern value.
That position stems from the courts' correct recognition that DCF analysis can provide the best measure of the value of the enterprise and that the value of the enterprise, alter deducting off the value of the debt, measures the value of the firm to its equity holders and thus its going concern value.
Class VI assets are all IRC section 197 intangibles, except goodwill and going concern value.
The total going concern value of Crystal Oil at the effective date, including cash on hand, is estimated at $130.
According to the federal Interagency Appraisal and Evaluation Guidelines issued in December 2010, going concern value reduced to its basic meaning is simply the value of a business entity rather than just the real property.
According to the IRS, trademarks and trade names are a component of a larger asset, which is either goodwill or going concern value or both.
California Revenue and Tax Code, [degrees][+ or -]110, specifically exempting intangible property from ad valorem taxation by stating in part, "[t]he value of intangible assets and rights to the going concern value of a business using taxable property shall not enhance or be reflected in the value of the taxable property.
Therefore, the Company is seeking court protection to maximize going concern value in an orderly manner," said Ed Sherrick, Chief Financial Officer.
The IRS believes that goodwill and going concern value are "so inherently unique and inseparable from the business" that they can never be of like kind with any other goodwill or going concern value (T.
Measuring business enterprise value (BEV) is an important part of many appraisal assignments, but debate continues over the appropriate techniques for extracting this component of going concern value.
A "section 197 intangible" -- which includes goodwill, going concern value, workforce in place, information base, know-how, customer-and supplier-based intangibles, governmental licenses and permits, covenants not to compete and other similar arrangements, franchises, trademarks, trade names, and contracts for the use of the foregoing assets -- is defined in Prop.
Commissioner, the taxpayer allocated the purchase price to the cost of the right to service mortgage loans, but the Tax Court allocated some of the purchase price to nondeductible goodwill and going concern value.