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amortization over the remaining life of the lease." Steinway &
Sons v. Commissioner, 46 T.C. 375, 381 (1966); sec. 1.162-11(a),
Income Tax Regs. It is clear, however, that the taxpayer must
have incurred some cost, by an outlay of consideration, as a
necessary prerequisite to the allowance of the deductions. A
leasehold is an intangible asset that is gradually exhausted by
the passage of time. Its cost is recoverable ratably by way of
amortization deductions over the period of exhaustion in the same
manner that costs of tangible assets are recoverable by way of
depreciation deductions. Of course, the amortization deductions
are in addition to those for rent required to be paid under the
lease. See Washington Package Store, Inc. v. Commissioner, T.C.
Memo. 1964-294.
We turn now to petitioner's principal argument that a
portion of the acquisition price is allocable to the Superdome
leasehold due to what petitioner refers to as "mutual
conditionality" between section 5.02 of the Sales Contract and
section K of the Revised Lease. Petitioner argues that the
"operative instruments [the Sales Contract and the Revised Lease]
wove the enhanced stadium lease into the fabric of the sale."
And, as such, petitioner further argues that it "was not liable
for the purchase price unless it received the Revised Lease, and
was entitled to the Revised Lease only if it paid the purchase
price." Accordingly, petitioner's argument concludes, the
conditions set forth in section 5.02 of the Sales Contract and
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