Roy H. Park Broadcasting, Inc. v. Commissioner
United States Tax Court
In these consolidated cases, petitioners were the owners of various television and radio broadcasting stations, many of which had affiliation contracts with a national network.
Read the full summary
In these consolidated cases, petitioners were the owners of various television and radio broadcasting stations, many of which had affiliation contracts with a national network. With respect to the television network affiliation contracts at issue herein, petitioners contend that a component portion of their basis in each such contract, to wit, that portion of the basis attributable to revenues paid directly by the network to the station, had, during the years at issue, a fixed useful life the length of which could be estimated with reasonable accuracy. Accordingly, petitioners claimed their…
1Opinion of the Court
Sterrett, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Docket No. Taxable year ended Deficiency Petitioner
1550-73 Roy H. Park Broadcasting, Inc.June 30, 1966 $10,431.36
June 30, 1967 78,343.63
6237-73 June 30, 1968 173,448.31
1076-74 June 30, 1969 15,897.36
June 30, 1970 19,161.74
July 1, 1971
Oct. 31, 1971 38,361.06
3006-74 R. H. P., Inc. (Successor to State & Aurora, Inc.) Dec. 31, 1966 5,521.00
Dec. 31, 1967 131,926.00
After concessions, the issues for decision are (1) whether petitioners are entitled to amortize a portion of…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Reaver v. CommissionerUnited States Tax Court · 1964
- Taylor v. CommissionerUnited States Tax Court · 1977
14 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- United States v. Leona M. Helmsley, Joseph v. Licari and Frank J. Turco, Leona M. HelmsleyCourt of Appeals for the Second Circuit · 1991
- Banc One Corp. v. CommissionerUnited States Tax Court · 1985
- Grynberg v. CommissionerUnited States Tax Court · 1984
- Fischer Industries, Inc. v. CommissionerUnited States Tax Court · 1986
- Orin R. Woodbury and Imogene R. Woodbury v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1990
14 more not listed; retrieve them via the Exa API.