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all taxable years prior to 1991 aggregated $3,668 for termite
contracts and $125,576 for pest control contracts.
The parties stipulated that if this Court adopts
petitioners' position, SPC-SC and SPC-FL's allowable amortization
deductions for taxable years 1991 and 1992 and for each year
thereafter, until the remaining amortizable bases are exhausted,
will be as follows:
SPC-SC
Termite contracts:
Corrected amortizable basis $334,406
Divided by agreed 15-year useful life 15
Allowable amortization deduction 22,294
Pest control contracts:
Corrected amortizable basis $660,136
Divided by agreed 10-year useful life 10
Allowable amortization deduction 66,014
SPC-FL
Termite contracts:
Corrected amortizable basis $112,250
Divided by agreed 15-year useful life 15
Allowable amortization deduction 7,483
Pest control contracts:
Corrected amortizable basis $824,415
Divided by agreed 10-year useful life 10
Allowable amortization deduction 82,442
If, however, this Court adopts respondent's position, the
parties stipulated that SPC-SC and SPC-FL's allowable
amortization deductions for taxable years 1991 and 1992 and for
each year thereafter, until the remaining amortizable bases are
exhausted, shall be as follows:
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