Appellant taxpayer has brought this suit for refund of federal income taxes plus interest for the years 1969 and 1970 in the total sum of $13,888.50. It has taken this appeal from judgment of the district court in favor of the United States. Presented is the question of its right to take a loss deduction for accounts that formed part of a purchased customer list where the customer subsequently ceased or refrained from doing business with the taxpayer, or, alternatively, its right to take a depreciation deduction.

Taxpayer is a Portland, Oregon, corporation dealing in insurance. In 1968 it purchased all the capital stock of James A. Rossman Company, another Portland insurance company, for $125,000. The purchase price was allocated as follows by the parties to the sale: (1) $5,000 for bank accounts, accounts receivable, reserve for bad debts, furniture, fixtures and equipment; (2) $111,100 for the “accounts, files and dailies of each insured as listed and individually priced * * * (3) $8,900 for goodwill.

In 1969 and 1970 taxpayer ascertained which of the purchased accounts had ceased doing business with it, and on its income tax return deducted, as a loss under § 165(a) of the Internal Revenue Code of 1954, the amount allocated by it to such accounts on its purchase price list. On audit, the Commissioner of Internal Revenue determined that taxpayer was not entitled to deduct such amounts as losses. Assessments were made for deficiencies in these respects and were paid by the taxpayer. Claims for refund were filed and disallowed, and this action was brought to recover the amounts disallowed, plus statutory interest. The taxpayer contended in the alternative (1) that it was entitled to a loss deduction on the accounts that had ceased doing business; (2) that it was entitled to depreciation on the accounts purchased. The district court rejected both of these contentions. Ralph W. Fullerton Co. v. United States, 381 F.Supp. 1353 (D.Or. 1974). We affirm.

1. Loss Deduction

On this aspect of the appeal the controlling case is Sunset Fuel Co. v. United States, 519 F.2d 781 (9th Cir. 1975). The issue there was whether the mass asset rule should apply. We held that it should and approved the Commissioner’s position with reference to the rule:

519 F.2d at 783 .

We also stated:

519 F.2d at 783 .

Appellant contends that the record establishes that the purchased accounts were not a mass asset, that they were valued individually and that the portion of the total purchase price allocated to each particular account was specifically set forth. We cannot agree.

Hendrik Grootendorst, vice-president of taxpayer, evaluated the accounts for taxpayer by the following procedures: first, he eliminated all accounts felt to be without renewal value, such as guardian bonds; second, as to the remaining accounts (with one exception), he took the gross annual commission and multiplied it by two. James Rossman, former owner of the Ross-man agency, testified that two times the annual commission was the “going rate” for calculating the purchase price of an insurance business.

Sunset Fuel made clear that valuation of customer accounts by resort to a formula applied indiscriminately to all accounts does not sufficiently establish the portion of the purchase price allocable to the individual accounts so as to avoid application of the mass asset rule. Indeed, resort to a formula was felt to be an indication that the individual value of the accounts cannot satisfactorily be ascertained. In Sunset Fuel a fuel oil customer list was valued by multiplying the gallonage purchased during the prior year by four cents. We stated:

519 F.2d at 783-84 . Later we stated:

519 F.2d at 785 .

To the same effect is Tomlinson v. Comm’r of Internal Revenue, 507 F.2d 723, 725 (9th Cir. 1974).

We conclude that the district court properly rejected the claimed loss deductions for accounts that had ceased doing business.

2. Depreciation

To depreciate intangible assets such as insurance expirations under 26 U.S.C. § 167 (a), the taxpayer must show that the assets are not goodwill and that they have a reasonably ascertainable limited useful life. Houston Chronicle Publishing Co. v. United States, 481 F.2d 1240, 1250 (5th Cir. 1973), cert. denied, 414 U.S. 1129 , 94 S.Ct. 867 , 38 L.Ed.2d 754 (1974); Rev.Rul. 74-456, 1974- 2 C.B. 65 .

Here the taxpayer did not establish as a factual matter that the assets in question had value separate from goodwill. Compare Marsh & McLennan, Inc. v. Comm’r of Internal Revenue, 420 F.2d 667, 669-70 (3d Cir. 1969), with Richard S. Miller & Sons, Inc. v. United States, 537 F.2d 446, 452-54 (Ct.Cl.1976). Comm’r of Internal Revenue v. Seaboard Finance Corp., 367 F.2d 646 (9th Cir. 1966), on which taxpayer relies, is distinguishable because it involved an unchallenged tax court finding that the intangible assets in question were properly allocated 30 per cent, to goodwill and 70 per cent, to depreciable values. Here the testimony of Grootendorst was to the effect that the figure of $8,900 for goodwill was arbitrarily fixed to bring the total purchase price up to $125,000, the figure demanded by Rossman and which taxpayer was willing to pay. In light of this, we need not consider the district court’s alternative ground for disallowing a depreciation deduction — the appellant’s failure to show a reasonably ascertainable limited useful life. See Potts, Davis & Co. v. Comm’r of Internal Revenue, 431 F.2d 1222 (9th Cir. 1970).

We conclude that the district court properly rejected taxpayer’s claim for depreciation.

Judgment affirmed.

. Other courts have used the “mass asset rule” to refer to situations where distinct assets are inextricably linked to goodwill and for that reason are not depreciable. See e. g. Houston Chronicle Publishing Co. v. United States, 481 F.2d 1240, 1249 (5th Cir. 1973), cert. denied, 414 U.S. 1129 , 94 S.Ct. 867 , 38 L.Ed.2d 754 (1974).