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Accordingly, we find no reason to limit the analysis of a new
RIC's useful life to the duration of investments invested in the
first 6 months of a RIC's existence. Furthermore, the evidence
fails to reveal any basis for determining an alternate useful
life. Therefore, we find that petitioner has failed to meet its
burden of establishing a limited life for the future benefits
obtained from the expenditures it incurred during the years in
issue.
Decision will be entered
under Rule 155.
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