Triangle Publications, Inc. v. Commissioner
United States Tax Court
1. Petitioner's subsidiary acquired from an unrelated party a franchise which petitioner had granted to that unrelated party. Prior to the expiration of the franchise as extended by an agreement with the subsidiary made prior to the acquisition of the franchise by the subsidiary petitioner liquidated the subsidiary and took over its assets and liabilities.
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1. Petitioner's subsidiary acquired from an unrelated party a franchise which petitioner had granted to that unrelated party. Prior to the expiration of the franchise as extended by an agreement with the subsidiary made prior to the acquisition of the franchise by the subsidiary petitioner liquidated the subsidiary and took over its assets and liabilities. Held, petitioner is entitled to deduct amortization for the unexpired portion of the franchise it acquired upon the liquidation of its subsidiary. 2. A payment in excess of the asset value of the corporation made by petitioner for the stock…
1Opinion of the Court
OPINION
The first issue presented for decision is whether petitioner is entitled to deduct as amortization or otherwise the amount of its subsidiary’s cost of purchase from an unrelated party of a TV Guide francMse from petitioner which the subsidiary had not recovered through amortization deductions at the time petitioner liquidated its subsidiary and took over its subsidiary’s assets and liabilities. Petitioner contends it is entitled to amortize the unrecovered cost of the francMse to its subsidiary as the cost of an intangible asset with a limited life used in its trade or business under…
2Cases cited6 opinions
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Pasadena City Lines, Inc. v. Commissioner (A)United States Tax Court · 1954
- Max Levine and Pennie Levine v. Commissioner of Internal Revenue, Jacob Dubrovsky and Gertrude Dubrovsky v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1963
- Fry v. CommissionerUnited States Tax Court · 1958
- Risko v. CommissionerUnited States Tax Court · 1956
1 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Herrick v. CommissionerUnited States Tax Court · 1985
- KFOX, Inc. v. United StatesUnited States Court of Claims · 1975
- Walt Disney Productions v. United States of America, Walt Disney Productions v. United StatesCourt of Appeals for the Ninth Circuit · 1973
- Florida Publishing Co. v. CommissionerUnited States Tax Court · 1975
- Ithaca Indus. v. CommissionerUnited States Tax Court · 1991
9 more not listed; retrieve them via the Exa API.