Alamo Broadcasting Co. v. Commissioner
United States Tax Court
Petitioner purchased all the equipment of Mexican radio station XENT in 1944 to obtain high-powered transmitting equipment made unavailable in the United States by wartime restrictions. Permission was obtained from the Mexican Government to bring out of Mexico the XENT transmitter but not the diesel power unit which was included in the equipment purchased.
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Petitioner purchased all the equipment of Mexican radio station XENT in 1944 to obtain high-powered transmitting equipment made unavailable in the United States by wartime restrictions. Permission was obtained from the Mexican Government to bring out of Mexico the XENT transmitter but not the diesel power unit which was included in the equipment purchased. In 1946, petitioner sold the diesel in Mexico, claiming that the loss on its disposition resulted from the sale of property used in the trade or business. Respondent determined that no loss was allowable on the ground that petitioner was…
1Opinion of the Court
OPINION.
Arundell, Judge:
The principal question here involves the loss claimed by petitioner on its sale of the diesel power unit. On its 1946 return, petitioner claimed a loss of $111,515.62. Its petition reduced the claimed loss to $107,715.62 and the brief further reduced it to $82,171.26.
Respondent’s theory for denying petitioner any loss is that the cost basis of the diesel was not in excess of the amount received for it since, according to respondent, petitioner intended the diesel for salvage at the time it purchased the total property, including the diesel, of Mexican radio station…
2Cases cited6 opinions
- P. Dougherty Co. v. CommissionerUnited States Tax Court · 1945
- Carter-Colton Cigar Co. v. CommissionerUnited States Tax Court · 1947
- Nachman v. CommissionerUnited States Tax Court · 1949
- Yellow Cab Co. of Pittsburgh v. DriscollDistrict Court, W.D. Pennsylvania · 1938
- East Kauai Water Co. v. CommissionerUnited States Tax Court · 1948
1 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Fox v. CommissionerUnited States Tax Court · 1951
- Shufflebarger v. CommissionerUnited States Tax Court · 1955
- Reithmeyer v. CommissionerUnited States Tax Court · 1956
36 more not listed; retrieve them via the Exa API.