Internal Revenue Service Department of the Treasury Number: 201317003 ...
Thus, because that useful life has elapsed under statute, the Termination Payment, although capital under ยง 1.263(a)-4(d)(7), should be fully amortized in the period in which it was made. 2. The portion of the Termination Payment made by Taxpayer to Franchisee that is allocable to the termination of the agreement entered into on Date 3, is ... ................
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