Indiana Broadcasting Corp. v. Commissioner
United States Tax Court
Petitioner acquired on November 30, 1956, the CBS network affiliation contracts of WISH-TV in Indianapolis and WANE-TV in Fort Wayne in connection with its acquisition of the assets of these stations. The total basis for all the assets was $ 11,098,800.67. The network affiliation contracts were for 2-year terms, automatically renewable for successive 2-year terms unless either party gives 6 months' written notice of intention not to renew. The contracts are still in force.
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Petitioner acquired on November 30, 1956, the CBS network affiliation contracts of WISH-TV in Indianapolis and WANE-TV in Fort Wayne in connection with its acquisition of the assets of these stations. The total basis for all the assets was $ 11,098,800.67. The network affiliation contracts were for 2-year terms, automatically renewable for successive 2-year terms unless either party gives 6 months' written notice of intention not to renew. The contracts are still in force. Held: 1. That of the total basis for the assets acquired by petitioner, $ 4,625,000 represented the cost of the two…
1Opinion of the Court
OPINION
Is the petitioner entitled to deductions for depreciation or amortization of CBS television network affiliation contracts it acquired by the purchase of television broadcasting stations WISH-TV and WANE-TV? That is the principal question presented in this case. The parties agree that its resolution involves the three subsidiary questions of (1) the proper allocation of basis to the contracts in accordance with their value, (2) whether such contracts constitute goodwill, and (3) whether the useful lives of such contracts can be estimated with reasonable accuracy, as required by section…
2Cases cited20 opinions
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- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
- Boe v. CommissionerUnited States Tax Court · 1961
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
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3Cited by36 opinions
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