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 assetPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011