Southern Multi-Media Commun., Inc. v. Commissioner
United States Tax Court
HELD: $ 1,927,396 in costs of certain improvements to cable television systems does not qualify for investment tax credit under the "supply or service" transition rule of sec. 204(a)(3) of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2149.
1Opinion of the Court
Swift, Judge:
For the years in issue, respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Year Deficiency
1990 . $3,318,947
1991 . 1,512,979
1992 . 2,272,661
1993 . 2,727,882
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After settlement of some issues, the issue remaining for decision is whether costs of certain improvements to petitioners’ cable television systems qualify for investment tax credit (ITC) under the supply…
2Cases cited9 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Tele-Communications, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1993
- Tele-Communications v. CommissionerUnited States Tax Court · 1990
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