Journal-Tribune Publishing Co. v. Commissioner
United States Tax Court
In 1941 the petitioner leased the newspaper businesses of two corporations for a period of 99 years. In the leases it agreed that it would exert its best endeavor in the upkeep and publication of the newspapers. In 1956 it purchased a new printing press and related equipment having a useful life in excess of 1 year, and discontinued use of, and sold, the old press.
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In 1941 the petitioner leased the newspaper businesses of two corporations for a period of 99 years. In the leases it agreed that it would exert its best endeavor in the upkeep and publication of the newspapers. In 1956 it purchased a new printing press and related equipment having a useful life in excess of 1 year, and discontinued use of, and sold, the old press. It claimed as an ordinary and necessary business expense deduction the cost of the new press accrued and paid prior to the close of its taxable year ended October 31, 1957. In a case involving the petitioner's tax liability for a…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the taxable years ended October 31,1955, and October 31,1957, in the respective amounts of $28,709.63 and $144,543.20.
The issue presented is whether, under the particular circumstances here involved, the petitioner is entitled to deduct as an ordinary and necessary business expense for the taxable year ended October 31, 1957, the cost of a new printing press. Involved is the question whether, under the doctrine of collateral estoppel, the parties are bound to any extent by a court decision relating to the petitioner’s tax…
2Cases cited25 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- The Evergreens v. NunanCourt of Appeals for the Second Circuit · 1944
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Fairmont Aluminum Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955
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3Cited by7 opinions
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- Five Star Mfg. Co. v. CommissionerUnited States Tax Court · 1963
- Journal-Tribune Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1965
- Estate of Bryan v. CommissionerUnited States Tax Court · 1963
- Five Star Mfg. Co. v. CommissionerUnited States Tax Court · 1963
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