FMR CORP. v. COMMISSIONER
United States Tax Court
P provides investment management services to regulated investment companies (RIC's), which are commonly referred to as mutual funds. During the years in issue, P incurred costs for developing and launching 82 new RIC's. The expenditures incurred in launching new RIC's were intended to, and did, provide significant future benefits to P. HELD: The expenditures are not currently deductible under sec. 162(a), I.R.C., and must be capitalized under sec. 263(a), I.R.C.
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P provides investment management services to regulated investment companies (RIC's), which are commonly referred to as mutual funds. During the years in issue, P incurred costs for developing and launching 82 new RIC's. The expenditures incurred in launching new RIC's were intended to, and did, provide significant future benefits to P. HELD: The expenditures are not currently deductible under sec. 162(a), I.R.C., and must be capitalized under sec. 263(a), I.R.C. HELD, FURTHER: P failed to establish a limited life for the future benefits obtained from the costs of launching RIC's. P may not…
1Opinion of the Court
FMR CORP. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
FMR CORP. v. COMMISSIONER
Tax Ct. Dkt. No. 15711-94
United States Tax Court
110 T.C. 402; 1998 U.S. Tax Ct. LEXIS 30; 110 T.C. No. 30;
June 18, 1998, Filed
Decision will be entered under Rule 155.
P provides investment management services to regulated investment companies (RIC's), which are commonly referred to as mutual funds. During the years in issue, P incurred costs for developing and launching 82 new RIC's. The expenditures incurred in launching new RIC's were intended to, and did, provide significant future…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. TellierSupreme Court of the United States · 1966
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
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