Kernrechtsfrage
Whether the taxpayers were entitled to continue amortizing the film investment for 1999/2000 under direct federal tax law.
Extrahierter Entscheid
No. The 1993 agreement only allowed limited amortizations for a fixed period and did not create a right to further deductions after that period ended.
Extrahierte Begründung
The court held that the agreement was to be interpreted by good faith and its purpose was merely to grant an extraordinary, time-limited relief. Once its effects expired, the remaining investment could not automatically be carried forward as deductible business assets.