Tribune Publishing Co. v. Commissioner
United States Tax Court
Petitioner, owner of an independent television station, was the licensee of various syndicated and feature films. Petitioner wrote off these films under a method which purportedly related payments to usage. Although petitioner filed its returns on an accrual basis, petitioner claimed in each year as the amount of its writeoff with respect to licensed films the same amount as were its payments to licensors during that year. Held, petitioner's method was not proper.
1Opinion of the Court
OPINION
The sole issue for decision is whether petitioner, an accrual method taxpayer, overstated its deductions for television film rentals in the taxable years 1957,1958, and 1959.
This opinion must be presented against the backdrop of KIRO, Inc., 51 T.C. 155 (1968), in which the Court considered the same issue. The dispute in that case focused on three categories of films: (1) 700 Paramount films (1 contract) having limited exposures. (2) 1,407 other films (35 contracts) having limited exposures. (3) Other films (5 contracts) having unlimited exposures. The taxpayer had allocated the cost of…
2Cases cited5 opinions
- KIRO, Inc. v. CommissionerUnited States Tax Court · 1968
- Early v. CommissionerUnited States Tax Court · 1969
- Portland General Electric Company v. United StatesDistrict Court, D. Oregon · 1960
- United States v. Portland General Electric Company, an Oregon CorporationCourt of Appeals for the Ninth Circuit · 1962
- Baker v. CommissionerUnited States Tax Court · 1962
3Cited by1 opinion
- Tribune Publishing Co. v. CommissionerUnited States Tax Court · 1969