- 17 - III. Tax Returns Petitioner claimed a tax basis for its favorable financing equal to its claimed fair market value at close of business on December 31, 1984. On its 1985 Federal income tax return, petitioner claimed that as of December 31, 1984, its favorable financing intangible assets had an aggregate amortizable value of $456,021,853.9 Petitioner now claims that its favorable financing intangible assets had an aggregate amortizable value of $428,391,551 on January 1, 1985.10 OPINION As part of the legislation that subjected petitioner to Federal income taxation, Congress enacted a dual-basis rule for 9 On its original Federal income tax returns for the years at issue, petitioner reported the aggregate adjusted bases of its favorable financing intangible assets as follows: Aggregate adjusted basis of favorable Year financing intangible assets 1985 $456,021,853 1986 391,552,352 1987 337,931,651 1988 283,234,501 1989 237,398,945 1990 196,718,525 Petitioner adjusted the bases of the favorable financing intangible assets for tax benefits received and the lost bases on retirements. 10 Petitioner reduced the value of its favorable financing intangible assets using the valuation performed by Dr. Stephen M. Schaefer.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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