- 13 - In Meredith I, we reasoned that contingent acquisition costs incurred through TYE 1991 were to be added to the cost basis of the subscriber relationships when they became fixed, and we held only that those costs attributable to Meredith's TYE 1986 and TYE 1987 were amortizable over whatever remained of the 42-month useful life ending June 30, 1989. We did not address the deductibility of editorial costs incurred in any year after TYE 1987 because such years were not before the Court. III. Contingent Acquisition Costs Attributable to Fully Amortized Assets Are Deductible as Incurred Furthermore, the expiration in mid-1989 of the useful life of the subscriber relationships does not foreclose a deduction for those editorial costs incurred by Meredith during subsequent taxable years. General tax law principles enounced in regulations and case law provide that contingent asset acquisition costs that become fixed after the relevant asset is fully amortized are deductible as they are incurred. Section 1.338(b)-3T, Temporary Income Tax Regs., 51 Fed. Reg. 3592 (Jan. 29, 1986), as adopted in T.D. 8072, 1986-1 C.B. 111, concerns the treatment of adjustments to adjusted grossed-up basis (AGUB) for contingent events that occur after the close of a new target's first taxable year in certain stock acquisitions. If an acquisition date asset has been disposed of, or fully depreciated, amortized, or depleted before a contingent amount is taken into account in determining AGUB, the contingent amountPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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