- 11 - It is true, as respondent points out, that the allocable purchase price exceeded the fair market value of the acquired tangible and amortizable intangible assets of LHJ. That does not dictate, however, that editorial costs incurred after the expiration of the 42-month useful life must be assigned to nonamortizable goodwill or going concern value. As we stated in Meredith I, "the sole reason why the subscriber relationships are not treated as goodwill is that they can be valued and have a limited useful life which can be estimated with reasonable accuracy". Meredith Corp. & Subs. v. Commissioner, 102 T.C. at 460. The aforementioned editorial costs were found to constitute part of the value of that asset, and not of goodwill. In arguing to the contrary, respondent ignores our rationale in Meredith I that such contingent costs were to be added "to the basis of the subscriber relationships in the years in which such amounts are incurred". Id. at 455 (emphasis added). The Court initially subtracted from Grabowski's income approach valuation of the subscriber relationships the present value of all of the stipulated editorial costs (including costs incurred during Meredith's TYE 1990 and TYE 1991) due to their contingency, and then prescribed adjustments for TYE 1986 and TYE 1987 based on the actual costs incurred by Meredith in each of those years. Id. at 463. It would be inconsistent with the analysis in Meredith I to deny petitioner an increase in thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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