FMR Corp. and Subsidiaries - Page 48

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               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.                                                       




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