Legal Opinion

Broadcast Measurement Bureau, Inc. v. Commissioner

United States Tax Court

Decided May 10, 1951No. Docket No. 21519PublishedCited by 39 opinions

Petitioner is a non-profit membership corporation whose members are the National Association of Broadcasters, the Association of National Advertisers, Inc., and the American Association of Advertising Agencies. Petitioner has been engaged in the compilation and distribution of nationwide surveys measuring radio station and network audiences according to a uniform standard.

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Petitioner is a non-profit membership corporation whose members are the National Association of Broadcasters, the Association of National Advertisers, Inc., and the American Association of Advertising Agencies. Petitioner has been engaged in the compilation and distribution of nationwide surveys measuring radio station and network audiences according to a uniform standard. Its first nationwide survey of stations and networks, Study No. 1, was commenced in March 1946 and was financed by subscription fees paid both by individual stations and networks. Petitioner's receipts for the fiscal year…

1Opinion of the Court

OPINION.

Hill, Judge:

The first question for our determination is whether petitioner realized any income in the fiscal year ended June 30, 1946. It is respondent’s contention that BMB realized net income in the amount of $99,370.19 in that year. This figure constitutes petitioner’s gross receipts, which came totally from subscription fees in these'12 months, less both its disbursements in that year for Study No. 1 and a net operating loss carried back from the fiscal year ended June 30, 1947. Petitioner argues that it had no gross income in the year under consideration on the ground that it…

2Cases cited9 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
  3. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  4. Commissioner v. WilcoxSupreme Court of the United States · 1946
  5. Krim-Ko Corp. v. CommissionerUnited States Tax Court · 1951

4 more not listed; retrieve them via the Exa API.

3Cited by39 opinions

  1. Mensik v. CommissionerUnited States Tax Court · 1962
  2. Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
  3. Angelus Funeral Home v. CommissionerUnited States Tax Court · 1967
  4. Illinois Power Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
  5. Johnson v. CommissionerUnited States Tax Court · 1997

34 more not listed; retrieve them via the Exa API.

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