Chronicle Pub. Co. v. Commissioner
United States Tax Court
P is the publisher of a daily newspaper. During 1983 and 1984, P claimed a charitable deduction for the contribution of its newspaper clippings library to a sec. 170(c)(2), I.R.C., charitable organization. Held, the newspaper clippings library is property similar to a letter or memorandum which was prepared or produced for P and is excluded from the definition of a capital asset under sec. 1221(3), I.R.C.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined deficiencies in petitioner’s 1983, 1984, and 1985 Federal income taxes in the following amounts:
Year Deficiency
1983. $691,835
1984. 211,121
1985. 441,625
The sole issue for decision is whether the newspaper clippings library (clippings library) contributed by petitioner to the California Historical Society, a section 170(c)(2)1 charitable organization, is ordinary income property under section 1221(3) and therefore subject to the limitation of section 170(e)(1)(A). This issue has been severed from other issues in the case and has been submitted to…
2Cases cited7 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
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3Cited by11 opinions
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