Toledo Newspaper Co. v. Commissioner
United States Tax Court
Where during the taxable year a taxpayer corporation engaged in the publication of a newspaper entered into a contract to sell all of its intangible assets for a specified consideration but no tangible assets, and in the same contract agreed for a separate specified consideration that it would discontinue publication of its newspaper on a given date, that it would not resume publication of any newspaper in the city of publication for a period of ten years, and that it would…
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Where during the taxable year a taxpayer corporation engaged in the publication of a newspaper entered into a contract to sell all of its intangible assets for a specified consideration but no tangible assets, and in the same contract agreed for a separate specified consideration that it would discontinue publication of its newspaper on a given date, that it would not resume publication of any newspaper in the city of publication for a period of ten years, and that it would not permit its plant or equipment to be used for the publication of any newspaper in said city for a like period, held,…
1Opinion of the Court
OPINION.
Black,- Judge:
As shown in our opening statement, the contested deficiencies result fram the respondent’s addition in Docket No. 110076 to the net loss disclosed by Toledo’s return for 1938 of “Income received under sales agreement with The Toledo Blade Company dated August 1,1938, $713,554.16”; and addition in Docket No. 110077 to the net loss disclosed by San Diego’s return for 1939 of “Income received under a sales agreement with The Union-Tribune Publishing Company dated November 17, 1939, $483,180.46.” Petitioners contest the entire difi-ciencies on the ground that both these…
2Cases cited1 opinion
- Helvering v. SalvageSupreme Court of the United States · 1936
3Cited by58 opinions
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Michaels v. CommissionerUnited States Tax Court · 1949
- Schmitz v. CommissionerUnited States Tax Court · 1968
- Horton v. CommissionerUnited States Tax Court · 1949
- Emmette L. Barran and Martha Barran v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
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