IRS sections 1060 and 338 provide rules for allocating assets transferred or acquired after February 13, 1977.  Under those rules, all amortizable section 197 intangibles (except for goodwill and going concern value) are included in Class IV assets.  Amortizable section 197 intangibles include workforce in place; business books and records, operating systems, and information base; patent, copyright, formula, process, design, pattern, know-how, format and other similar items; customer-based intangibles; supplier-based intangibles; licenses, permits, and other rights granted by government; covenant not to compete; and franchises (except for sports franchises), trademark, or trade name.  Intangible assets must be identifiable in order to distinguish them from goodwill (a residual asset).