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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