Inter-City Television Film Corp. v. Commissioner
United States Tax Court
Petitioner in 1954, 1955, and 1956 was the owner of contract rights to exhibit or license others to exhibit on television certain motion-picture films which it had acquired in five groups on which it was entitled to take amortization. Held, petitioner's basis as to one group was the amount of its fixed obligation to pay the vendor; a price reduction in a subsequent year will only affect the basis in the later years.
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Petitioner in 1954, 1955, and 1956 was the owner of contract rights to exhibit or license others to exhibit on television certain motion-picture films which it had acquired in five groups on which it was entitled to take amortization. Held, petitioner's basis as to one group was the amount of its fixed obligation to pay the vendor; a price reduction in a subsequent year will only affect the basis in the later years. Held, further, respondent failed to sustain his burden of showing the cost basis as to another group should be reduced, as alleged in his amendment to answer, merely because the…
1Opinion of the Court
MulRONEY, Judge:
Respondent determined deficiencies in the petitioner’s income tax for the fiscal years ended February 28, 1955, February 29, 1956, and February 28, 1957, in the respective amounts of $218,251.67, $112,995.81, and $56,091.31. In an amendment to his answer the respondent claimed an increased deficiency for the fiscal year 1955 in the total amount of $366,137.59, and in a second amendment to his answer (filed after the trial) the respondent claimed an increased deficiency for the fiscal year 1955 in the total amount of $374,158.25.
The issues are (1) the determination of the…
2Cases cited17 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Burnet v. LoganSupreme Court of the United States · 1931
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
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3Cited by25 opinions
- Fox v. CommissionerUnited States Tax Court · 1983
- Underhill v. CommissionerUnited States Tax Court · 1966
- Lemery v. CommissionerUnited States Tax Court · 1969
- Greene v. CommissionerUnited States Tax Court · 1983
- KIRO, Inc. v. CommissionerUnited States Tax Court · 1968
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