Toledo TV Cable Co. v. Commissioner
United States Tax Court
Held, on the facts presented the petitioners have failed to carry their burden of proving that certain municipal franchises for CATV have determinable useful lives. Accordingly, the respondent's determination that deductions for depreciation under sec. 167 (a), I.R.C. 1954, with respect to these franchises were not allowable is sustained.
1Opinion of the Court
Sterrett, Judge:
Respondent determined deficiencies in the petitioners’ Federal corporation income taxes as follows:
TYM Oct. SI— Deficiency
Toledo TV Cable Co., docket No. 861-69. 1966 1 $2, 560. 62
Newport TV Cable Co., docket No. 862-69 1963 1964 1965 1966 3, 726. 94 4, 628. 88 5,834. 52 5,034.10
1 Although by reason of a net operating loss deduction the respondent determined a deficiency for 1966 only, the statutory notice also covers Toledo Cable’s taxable years ended Oct. 31,1963,1964, and 1965.
The sole issue for decision is whether the respondent erred in determining that certain municipal…
2Cases cited14 opinions
- 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
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Nachman v. CommissionerUnited States Tax Court · 1949
- Kwtx Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
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3Cited by34 opinions
- Finoli v. CommissionerUnited States Tax Court · 1986
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- Ithaca Indus. v. CommissionerUnited States Tax Court · 1991
- Roy H. Park Broadcasting, Inc. v. CommissionerUnited States Tax Court · 1971
- Uecker v. CommissionerUnited States Tax Court · 1983
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