United States Tax Court

“ To determine whether the useful lives as so computed are appropriate to use in computing depreciation for petitioners would require a reopening of the record to permit the accountant to give her opinion testimony and to afford respondent the opportunity to cross-examine with respect to her opinion, and, if appropriate, to offer the opinion of another accounting expert. ”

“ Clearly here the record does not actually disclose the useful life of each of the assets involved which remained at the time petitioners received the assets from est, a.e.c. From the affidavit of the accountant and computations attached thereto we conclude that the computed remaining useful life of each asset is an accounting opinion of the accountant who did the computations and raises a new issue as to whether in fact these computations do properly result in the remaining useful life of each asset. ”

“ The useful life which should be applied to the basis of the assets to compute depreciation on a straight line basis; (2) whether an amount which petitioners paid over to the Internal Revenue Service as a withholding tax on interest due to Intercultural Cooperation Foundation (ICF) , an organization established under the laws of Switzerland, should be considered as a payment of tax made by petitioners and, if so, how it should be reflected in the computations under Rule 155 and decisions of the Court ”