Chronicle Publishing Co. v. Commissioner
United States Tax Court
Held: In the light of all the facts, the useful lives of 18 cable television franchises owned by petitioner's controlled group of subsidiaries during 1967 through 1971 were estimable with reasonable accuracy within the meaning of sec. 1.167(a)-3, Income Tax Regs. Accordingly, on its consolidated Federal income tax returns for those years, petitioner is entitled to depreciation deductions in respect of those franchises and related easements under sec. 167(a), I.R.C. 1954.
1Opinion of the Court
Featherston, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Year Deficiency Year Deficiency
1967. $2,528 1970. $50,850
1968. 6,046 1971. 56,195
1969. 40,788
A concession having been made by respondent, the only issue remaining for decision is whether the useful lives of cable television franchises and easements related thereto owned by petitioner’s subsidiaries can be estimated with reasonable accuracy so that depreciation deductions in respect of those assets are allowable under section 167(a)(1).1
FINDINGS OF FACT
1. General
Petitioner, the Chronicle…
2Cases cited15 opinions
- United States v. Southwestern Cable Co.Supreme Court of the United States · 1968
- Fortnightly Corp. v. United Artists Television, Inc.Supreme Court of the United States · 1968
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Kwtx Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
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3Cited by7 opinions
- Finoli v. CommissionerUnited States Tax Court · 1986
- Canterbury v. CommissionerUnited States Tax Court · 1992
- Liquid Paper Corp. v. United StatesUnited States Court of Claims · 1983
- Wenzel v. CommissionerUnited States Tax Court · 1991
- Canterbury v. CommissionerUnited States Tax Court · 1992
2 more not listed; retrieve them via the Exa API.