- 11 - respondent became aware of any additional facts that rendered his position any more or less justified between the issuances of the notices of deficiency and the filing of the answer to the petitions. Respondent contended that only property whose economic usefulness cannot be adequately measured by its physical condition or the passage of time and that may produce an uneven stream of income is properly depreciated under the income forecast method. Respondent’s position was based on the reasoning of Rev. Rul. 60-358, 1960-2 C.B. 68. In that ruling, the Commissioner determined that the usefulness of a television film was more adequately measured by reference to the income it produced than by the passage of time alone. The ruling explicitly stated that the income forecast method was “limited in its application to television films, taped shows for reproduction, and other property of similar character.” Rev. Rul. 60-358, 1960-2 C.B. at 70 (emphasis added). In later revenue rulings, the Commissioner amplified Rev. Rul. 60-358, 1960-2 C.B. by authorizing the use of the income forecast method to depreciate motion picture films, see Rev. Rul. 64-273, 1964-2 C.B. 62, book manuscripts, patents, and master recordings, see Rev. Rul. 79-285, 1979-2 C.B. 91. These rulings were based on section 167, which was, at the time the rulings were issued, the only provision governing depreciation. In the late 1980's, afterPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011