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(excluding maintenance expense) of the asset to the periods to
which it contributes." Id. at 553 (quoting Massey Motors, Inc.
v. United States, 364 U.S. 92, 104 (1960). Petitioners argue
that, where, as in the instant case, there has been no change to
the useful life or salvage value (zero in the instant case),
basing the annual amortization allowance to be deducted (until
the amortizable basis of the asset has been exhausted) on the
correctly determined original amortizable bases of the assets
would more accurately reflect the annual year concept.
The parties have agreed that the amortizable bases of the
acquired contract rights should be reduced by 15 percent, in
effect reallocating the purchase price among amortizable and
nonamortizable assets. This reallocation, and the resulting
corrected amortizable bases, is similar to a purchase price
reduction that will affect the calculation of the amount of
amortization to be deducted in subsequent taxable years. See,
e.g., Inter-City Television Film Corp. v. Commissioner, 43 T.C.
270, 286 (1964). To calculate the bases for amortization for the
years in issue, section 1016(a)(2) requires that the corrected
amortizable bases be further reduced by the greater of
amortization allowed or allowable. Computing & Software Inc. v.
Commissioner, 65 T.C. 1153, 1154 (1976).
Petitioners do not deny that the adjusted bases of the
acquired contract rights must be reduced by the greater of
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