- 48 - Petitioner conducted studies to determine the useful life of a new RIC based solely on the estimated duration of the initial investments in a new RIC from customers who invested during the first 6 months of the existence of the RIC. Petitioner argues that the reason a 6-month time period was selected for this study is that during the taxable years in issue, current performance information about a new mutual fund was not available for the first 6 months after a new RIC's introduction. Thus, petitioner posits, any investors who decided to invest in a new mutual fund during the first 6 months after its introduction would necessarily have based their decision on factors other than current performance. In petitioner's view, these are the only investors that conceivably could be attributed to the actions undertaken by petitioner during the period prior to the launch date of a new RIC. Petitioner provides no support for its assumption that the benefits of the expenditures it incurred were limited solely to initial investors.21 In fact, we have found that the benefits received from the RIC launching costs were significant and long lasting and certainly not limited to initial investments. 21Petitioner submitted the expert report of Fred C. Lindgren, an actuary with Coopers & Lybrand L.L.P. Although Mr. Lindgren's report set forth in great detail the methodology and statistics used to determine the average useful life of these initial investments, he relied upon petitioner's request to focus on investments made in the first 6 months rather than his own independent analysis.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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