Legal Opinion

WHEC, Inc. v. Commissioner

United States Tax Court

Decided January 24, 1962No. Docket No. 87133Published

Certain expenditures made by petitioner in 1956 in perfecting the grant in 1953 of a construction permit for a television station, which grant had been made without a hearing and as such was subject to protest and was in fact protested, held, to be capital expenditures and not deductible in 1956 as ordinary and necessary expenses under section 162(a), I.R.C. 1954.

1Opinion of the Court

WHEC, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

WHEC, Inc. v. Commissioner

Docket No. 87133

United States Tax Court

37 T.C. 821; 1962 U.S. Tax Ct. LEXIS 204;

January 24, 1962, Filed

Decision will be entered for the respondent.

Certain expenditures made by petitioner in 1956 in perfecting the grant in 1953 of a construction permit for a television station, which grant had been made without a hearing and as such was subject to protest and was in fact protested, held, to be capital expenditures and not deductible in 1956 as ordinary and necessary expenses under section 162(a),…

2Cases cited9 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Radio Station WBIR, Inc. v. CommissionerUnited States Tax Court · 1959
  3. Kwtx Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
  4. KWTX Broadcasting Co. v. CommissionerUnited States Tax Court · 1959
  5. Federal Broadcasting System, Inc. v. Federal Communications Commission, Whec, Inc., Intervenor, Veterans Broadcasting Company, Inc., IntervenorCourt of Appeals for the D.C. Circuit · 1955

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