Oak Industries, Inc. v. Commissioner
United States Tax Court
Ps were members of a partnership that conducted an over-the-air subscription television operation. The partnership transmitted an over-the-air scrambled signal from a broadcast studio. Subscribers were able to receive the unscrambled signal in their homes through an electronic decoder box. At the time of installation, each subscriber paid the partnership a deposit for the decoder which was refundable when the decoder was returned.
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Ps were members of a partnership that conducted an over-the-air subscription television operation. The partnership transmitted an over-the-air scrambled signal from a broadcast studio. Subscribers were able to receive the unscrambled signal in their homes through an electronic decoder box. At the time of installation, each subscriber paid the partnership a deposit for the decoder which was refundable when the decoder was returned. In Oak Industries, Inc. v. Commissioner, T.C. Memo. 1987-65, this Court held that Ps were required to include their distributive share of the security deposits…
1Opinion of the Court
OPINION
NlMS, Chief Judge:
This case is before the Court for reconsideration of the opinion in Oak Industries, Inc. v. Commissioner, T.C. Memo. 1987-65, filed January 29, 1987. The sole issue for decision is whether the opinion in Oak Industries, Inc. v. Commissioner, supra, should be revised due to the Supreme Court’s decision in Commissioner v. Indianapolis Power & Light Co., 493 U.S. 203 (1990), filed January 9, 1990.
By statutory notice of deficiency dated August 10, 1984, respondent determined deficiencies in petitioners’ Federal income taxes for 1974, 1977, and 1978 in the amounts of…
2Cases cited15 opinions
- 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
- Commissioner v. Indianapolis Power & Light Co.Supreme Court of the United States · 1990
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
10 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Johnson v. CommissionerUnited States Tax Court · 1997
- Kansas City S. Indus. v. CommissionerUnited States Tax Court · 1992
- Highland Farms v. CommissionerUnited States Tax Court · 1996
- American Valmar International Ltd., Inc. & Valeri Markovski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2000
- Houston Industries Inc. v. United StatesUnited States Court of Federal Claims · 1994
13 more not listed; retrieve them via the Exa API.