Meredith Corporation & Subsidiaries - Page 6

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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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