110 T.C. No. 30 UNITED STATES TAX COURT FMR CORP. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15711-94. Filed June 18, 1998. P provides investment management services to regulated investment companies (RIC's), which are commonly referred to as mutual funds. During the years in issue, P incurred costs for developing and launching 82 new RIC's. The expenditures incurred in launching new RIC's were intended to, and did, provide significant future benefits to P. Held: The expenditures are not currently deductible under sec. 162(a), I.R.C., and must be capitalized under sec. 263(a), I.R.C. Held, further: P failed to establish a limited life for the future benefits obtained from the costs of launching RIC's. P may not amortize such costs under sec. 167, I.R.C.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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