Legal Opinion

Flynn, Harrison & Conroy v. Commissioner

United States Board of Tax Appeals

Decided November 12, 1930No. Docket No. 28322PublishedCited by 11 opinions

Where a valuable contract having a definite term is acquired by purchase and is used in the business of the taxpayer, its cost may be exhausted over the remainder of the term.

1Opinion of the Court

*286OPINION.

Matthews :

As the contract had a fair value of $25,346.61 on July 12, 1921, the date it was acquired by petitioner, and the stock issued therefor also had a fair value of $25,346.61, the cost of the contract *287to petitioner was $25,346.61. The petitioner operated under the contract from the date of its acquisition until December 31,1922. Since the contract was property acquired by petitioner at a cost of $25,346.61 and was used in the business, it is necessary for us to determine only whether the contract had such a definite life as to entitle petitioner to a deduction for exhaustion of…

2Cited by11 opinions

  1. Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
  2. Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
  3. Inter-City Television Film Corp. v. CommissionerUnited States Tax Court · 1964
  4. Gulf Tel. Corp. v. CommissionerUnited States Tax Court · 1969
  5. Sumers v. CommissionerUnited States Tax Court · 1961

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