Artnell Co. v. Commissioner
United States Tax Court
Petitioner's transferor, a professional baseball corporation, excluded from gross income all advance receipts from tickets, radio and television, and parking fees, which related to games to be played in the following taxable year. The transferor corporation was then liquidated before such games were played.
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Petitioner's transferor, a professional baseball corporation, excluded from gross income all advance receipts from tickets, radio and television, and parking fees, which related to games to be played in the following taxable year. The transferor corporation was then liquidated before such games were played. Held, such advance receipts are taxable when received, regardless of the liquidation; except that the amounts collected as Federal admissions tax are a trust fund and not part of the collector's gross income.
1Opinion of the Court
Simpson, Judge:
The respondent has asserted that the petitioner is liable for $563,170.12 as transferee of the assets of Chicago White Sox, Inc. Such liability arises from a determination of deficiency in the transferor’s income tax of $303,109.07 for its taxable year November 1,1961, to May 31,1962. The respondent also disallowed a net operating loss carryback from such taxable year to the transferor’s taxable year January 1,1959, to October 31,1959, and, as a result, determined a deficiency of $260,061.05 for that taxable year.
The first issue is whether advance receipts from ticket sales,…
2Cases cited15 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
- Schulde v. CommissionerSupreme Court of the United States · 1963
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
10 more not listed; retrieve them via the Exa API.
3Cited by34 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Artnell Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
- Johnson v. CommissionerUnited States Tax Court · 1997
- S. Garber, Inc. v. CommissionerUnited States Tax Court · 1969
- New England Tank Industries, Inc. v. CommissionerUnited States Tax Court · 1968
29 more not listed; retrieve them via the Exa API.