- 12 - basis of its subscriber relationships for the editorial costs and associated tax benefits becoming fixed in its TYE 1990. II. Meredith I Does Not Preclude Petitioner's Deduction for Editorial Costs Incurred During Its TYE 1990 Respondent alternatively contends that "Nothing in the Court's Opinion in Meredith I even remotely suggests that Petitioner is entitled to an ordinary deduction [in its TYE 1990]" for additional contingent costs becoming fixed in that year. Nothing, however, in our Opinion suggests otherwise. Respondent nonetheless claims that "strictly speaking, the Court's Opinion [in Meredith I] precludes the deduction claimed by * * * [Meredith] for the taxable year ended June 30, 1990 * * * [because of the expiration of the stipulated 42-month useful life]". She cites the following language from Meredith I to support her proposition: The amounts are not subject to a new depreciation schedule, but, rather, are to be depreciated over the remaining useful life of the subscriber relationships based on a useful life ending 42 months after the acquisition of the subscribers. * * * Meredith Corp. & Subs. v. Commissioner, 102 T.C. at 462-463. However, the language above is inapposite to Meredith's TYE 1990 at issue in the instant matter. Placed in context, the words "the amounts" refer to the 1986 and 1987 additions to basis only. The penultimate sentence before the quotation computes dollar amounts for 1986 and 1987. Moreover, the sentence before the quoted language refers to "these amounts", meaning the 1986 and 1987 sums.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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