Update
[QUOTE=HiltonL;78079]I like this topic, it's very interesting.
I believe in Larmil's Wrigley case, I would be forced to use zero as a basis. Given the facts of original basis being "decades ago" any actual basis would be minute. Even if the TP did pay for the research, the difference in tax might be 15% of a thousand or two, so $300? How much cost do we want to incur to get that last % of accuracy?
I have talked to the client again. He had done considerable research and agrees the Cohan Rule would save him little. He was prepared at the outset to use a zero basis.
[QUOTE=HiltonL;78079]I like this topic, it's very interesting.
I believe in Larmil's Wrigley case, I would be forced to use zero as a basis. Given the facts of original basis being "decades ago" any actual basis would be minute. Even if the TP did pay for the research, the difference in tax might be 15% of a thousand or two, so $300? How much cost do we want to incur to get that last % of accuracy?
I have talked to the client again. He had done considerable research and agrees the Cohan Rule would save him little. He was prepared at the outset to use a zero basis.
Comment