Successful Farming Pub. Co. v. Commissioner
United States Board of Tax Appeals
The cost of building up a magazine circulation structure is a capital expenditure while the cost of maintaining a circulation structure, once established, is an ordinary and necessary business expense.
1Opinion of the Court
OPINION.
Lansdon :
The respondent has asserted deficiencies in income taxes for the calendar years 1922 and 1923, in the respective amounts of $12,694.43 and $9,213.31. The petitioner contends (1) that amounts expended in establishing and maintaining a magazine circulation structure are deductible as ordinary and necessary business expenses, and (2) in the alternative that if such expenditures are of a capital nature, they should be amortized over the life of the subscription contracts.
The record in this proceeding includes a voluminous stipulation of facts entered into by the parties and filed…
2Cited by16 opinions
- Thrifticheck Service Corp. v. CommissionerUnited States Tax Court · 1960
- Florida Publishing Co. v. CommissionerUnited States Tax Court · 1975
- Metropolitan Laundry Co. v. United StatesDistrict Court, N.D. California · 1951
- National Weeklies v. Com'r of Internal RevenueCourt of Appeals for the Eighth Circuit · 1943
- Drybrough v. CommissionerUnited States Tax Court · 1966
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