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incurred in petitioner's TYE 1986 and TYE 1987 to be amortized
over whatever remained of the stipulated 42-month useful life of
the subscriber relationships. Id. at 462-463. No appeal was
taken from the Court's decision.
On April 9, 1993, Meredith filed a petition in this Court
involving the same subscriber relationships issue for its TYE
1988. Meredith Corp. & Subs. v. Commissioner, docket No. 7166-93
(Meredith II). Meredith and respondent filed a Joint Motion for
Continuance (Joint Motion) in Meredith II since the Meredith I
opinion was not anticipated prior to the Meredith II trial date.
In the Joint Motion, the parties stated:
The amortization issues in the above-captioned case
relate to the years subsequent to the year of the
initial transaction, 1986, and as such, the parties
anticipate that resolution of the amortization issues
in the 1986 and 1987 taxable years will form the basis
for settlement of the issues in this case.
Meredith II was thereafter settled by the parties, using the
exact methodology set forth by the Court in Meredith I. This
Court entered a decision in Meredith II on October 4, 1994.
The same issue arising in Meredith's TYE 1989 was
subsequently settled with the IRS Appeals Office in Des Moines,
Iowa, applying, without dispute, the identical method used in
Meredith I and Meredith II. In a letter to petitioner dated June
29, 1995, respondent notified Meredith that the Joint Committee
on Taxation (Joint Committee) had officially informed her that it
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