Applying the 15-year amortization regs. for intangibles in a partnership setting

To end the controversy surrounding the treatment of intangibles such as goodwill and going-concern value, Congress allowed such items to be amortized over a 15-year period. To reduce the potential for abuse via bootstrap acquisitions of such property, however, Congress included complicated anti-churning rules. When these Section 197 rules are applied in the context of all the usual partnership rules for contributions, distributions. Section 754 elections and attendant basis adjustments, and curative and remedial allocations, the result is neither simple nor user friendly.