Schochet v. Commissioner
United States Tax Court
Petitioner is organized to collect monthly payments from franchisees of Insty-Prints, Inc. which payments are to be used solely for the advertising and promotion of the Insty-Prints business. Petitioner also earned interest on payments which were not currently expended by it. Held: Payments received by petitioner for advertising and promotion are not income to petitioner.
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Petitioner is organized to collect monthly payments from franchisees of Insty-Prints, Inc. which payments are to be used solely for the advertising and promotion of the Insty-Prints business. Petitioner also earned interest on payments which were not currently expended by it. Held: Payments received by petitioner for advertising and promotion are not income to petitioner. Ford Dealers Advertising Fund, Inc. v. Commissioner,55 T.C. 761 (1971), affd. per curiam 456 F.2d 255 (5th Cir. 1972) and Seven-Up Co. v. Commissioner,14 T.C. 965 (1950) followed. Held further: Interest earned by petitioner…
1Opinion of the Court
FRANK AND FREDA SCHOCHET, TRUSTEES OF INSTY-PRINTS, INC. NATIONAL ADVERTISING FUND TRUST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Schochet v. Commissioner
Docket No. 5493-79.
United States Tax Court
T.C. Memo 1982-416; 1982 Tax Ct. Memo LEXIS 326; 44 T.C.M. (CCH) 556; T.C.M. (RIA) 82416;
July 26, 1982.
Petitioner is organized to collect monthly payments from franchisees of Insty-Prints, Inc. which payments are to be used solely for the advertising and promotion of the Insty-Prints business. Petitioner also earned interest on payments which were not currently expended by it.…
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- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Morrissey v. CommissionerSupreme Court of the United States · 1935
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
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- Affiliated Foods, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1998