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In 1889 P got a 50-year franchise to operate a railway system in Philadelphia. P then built a bridge over the Schuylkill River at a cost of $381,000. In 1934, it deeded the bridge to the city in exchange for a ten-year extension of its franchise. The extended franchise was abandoned in 1946 with three years left to run on it. A dispute erupted over the basis for the ten-year extension. P asserted depreciation deductions based on the cost of the extension and a loss upon abandonment of the franchise. D contends that the bridge was either worthless or not exchanged for the 10-year extension.

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