Zakon v. Commissioner
United States Board of Tax Appeals
1. A license to sell liquor in the City of Boston, which, under a long continued custom, entitled the holder to a renewal from year to year and which renewal privilege was valuable, is property. 2. Petitioner purchased such a license in 1911, paying $11,000 for the renewal privilege. The value thereof was greater on March 1, 1913, than the cost.
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1. A license to sell liquor in the City of Boston, which, under a long continued custom, entitled the holder to a renewal from year to year and which renewal privilege was valuable, is property. 2. Petitioner purchased such a license in 1911, paying $11,000 for the renewal privilege. The value thereof was greater on March 1, 1913, than the cost. The license continued to have a substantial value which attached to the renewal privilege until 1919, when it became worthless because of national prohibition. Held, that petitioner sustained a loss in 1919 measured by the cost of the property to him.…
1Opinion of the Court
*689OPINION.
Phillips :
It appears that in 1911 and prior thereto the number of liquor licenses which might be issued in the City of Boston was limited by the laws of Massachusetts to not more than 1,000 and that such number might be further limited by the licensing board of the City of Boston in its discretion. This board did limit the number to 984 and refused to issue any larger number. While such licenses were issued annually, expiring on May 1 of each year, it was the established custom of the board to issue such annual licenses to the holders of licenses for the previous year. The holders of…
2Cases cited3 opinions
- United States v. FlannerySupreme Court of the United States · 1925
- McCaughn v. LudingtonSupreme Court of the United States · 1925
- Tracy v. GinzbergSupreme Court of the United States · 1907
3Cited by17 opinions
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Coors Porcelain Co. v. CommissionerUnited States Tax Court · 1969
- Hollywood Baseball Ass'n v. CommissionerUnited States Tax Court · 1964
- General Dynamics Corp. v. BullockTexas Supreme Court · 1976
- Keller Street Development Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
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