Wood County Tel. Co. v. Commissioner
United States Tax Court
In 1961, petitioner, a telephone company, purchased the entire assets of a neighboring telephone company, Rudolph, in order to expand its territory. The purchase was conditioned upon petitioner obtaining an order from the State regulatory agency allowing it to furnish telephone service to the area formerly serviced by Rudolph. Such an order was granted to petitioner for an indeterminate period.
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In 1961, petitioner, a telephone company, purchased the entire assets of a neighboring telephone company, Rudolph, in order to expand its territory. The purchase was conditioned upon petitioner obtaining an order from the State regulatory agency allowing it to furnish telephone service to the area formerly serviced by Rudolph. Such an order was granted to petitioner for an indeterminate period. At the time of purchase, petitioner intended to abandon most of the former Rudolph assets in order to convert the former Rudolph facility from a manual to a dial system. Held: 1. Upon converting the…
1Opinion of the Court
Wood County Telephone Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Wood County Tel. Co. v. Commissioner
Docket No. 971-66
United States Tax Court
51 T.C. 72; 1968 U.S. Tax Ct. LEXIS 43;
October 21, 1968, Filed
Decision will be entered for the respondent.
In 1961, petitioner, a telephone company, purchased the entire assets of a neighboring telephone company, Rudolph, in order to expand its territory. The purchase was conditioned upon petitioner obtaining an order from the State regulatory agency allowing it to furnish telephone service to the area formerly serviced by Rudolph.…
2Cases cited8 opinions
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Dresser v. United StatesUnited States Court of Claims · 1932
- Lynchburg Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1953
- Providence Journal Co. v. BroderickCourt of Appeals for the First Circuit · 1939
- Hillside Nat'l Bank v. CommissionerUnited States Tax Court · 1961
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