No Synergistic Benefits Intangible Existed and Therefore No Ordinary Loss Was Deductible on a Worthless Intangible

In Technical Advice Memorandum 202004010[1] the IRS ruled that a taxpayer (Taxpayer) could not treat “post-acquisition synergies” as an intangible asset into which costs incurred by a subsidiary(Target) when Taxpayer purchased it could be capitalized and then written off as an ordinary loss under IRC §165(a) when the Taxpayer decided to dispose of Target.

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