Meredith Corporation & Subsidiaries - Page 12

                                       - 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

Last modified: May 25, 2011