Meredith Corporation & Subsidiaries - Page 1

                                   108 T.C. No. 7                                     

                               UNITED STATES TAX COURT                                

                 MEREDITH CORPORATION & SUBSIDIARIES, Petitioner v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18248-95.            Filed February 27, 1997.               

                    P moved for partial summary judgment, claiming                    
               that it is entitled to a $1,555,428 ordinary deduction                 
               in its TYE 1990 stemming from contingent asset                         
               acquisition costs that became fixed in that year, after                
               the expiration of the useful life of the asset to which                
               they correspond.  R objected to P's motion and filed a                 
               cross-motion for partial summary judgment, arguing:                    
               (1) the contingent asset acquisition costs were not                    
               attributable to the subscriber relationships asset but                 
               must be allocated to nonamortizable intangibles; and,                  
               in the alternative, (2) the expiration of the useful                   
               life of the subscriber relationships bars any further                  
               cost recovery by P.  Held:  The contingent acquisition                 
               costs at issue are allocable to the basis of the                       
               subscriber relationships in P's TYE 1990.  Meredith                    
               Corp. & Subs. v. Commissioner, 102 T.C. 406 (1994),                    
               followed.  Held, further, P is entitled to an ordinary                 
               deduction in full in its TYE 1990 for contingent asset                 

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