Goodson-Todman Enterprises, Ltd. v. Commissioner
United States Tax Court
Petitioner is the producer of the game show, "To Tell The Truth" (TTTT). During the years in question, petitioner claimed investment tax credits for its costs incurred in connection with the production, for syndication, of TTTT tapes.
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Petitioner is the producer of the game show, "To Tell The Truth" (TTTT). During the years in question, petitioner claimed investment tax credits for its costs incurred in connection with the production, for syndication, of TTTT tapes. Respondent disallowed the credits based on his determination that the tapes did not qualify for the investment tax credit under secs. 38 and 48(k)(1)(B), I.R.C. 1954. Held: Petitioner's TTTT tapes constituted qualified films within the meaning of sec. 48(k)(1)(B), since they were "created primarily for use as public entertainment" and since the market for those…
1Opinion of the Court
Sterrett, Judge-.
In his notice of deficiency dated March 26, 1981, respondent determined deficiencies in petitioners’ Federal income taxes for the taxable years ended March 31, 1973, March 31, 1974, and March 31, 1977, in the respective amounts of $33,604, $160,587, and $11,482.1 The ultimate issue for decision is whether, pursuant to sections 38 and 48(k), I.R.C. 1954, petitioners are entitled to claim investment tax credits with respect to the videotaped television series, "To Tell The Truth.”
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts,…
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Dunn v. CommissionerUnited States Tax Court · 1978
- Commissioner v. EngleSupreme Court of the United States · 1984
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- Cosby v. United StatesUnited States Court of Claims · 1985
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