Radio Station WBIR, Inc. v. Commissioner
United States Tax Court
Petitioner, a corporation which operated a radio AM and FM broadcasting station, incurred attorney fees, engineering fees, and related expenses during the year 1953 in connection with its prosecution of an application for a television construction permit and television license before the Federal Communications Commission.
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Petitioner, a corporation which operated a radio AM and FM broadcasting station, incurred attorney fees, engineering fees, and related expenses during the year 1953 in connection with its prosecution of an application for a television construction permit and television license before the Federal Communications Commission. The television construction permit was granted by the Federal Communications Commission in 1956. Action on the application for a television license has been deferred pending determination of litigation involving the grant to petitioner of the construction permit. 1. Held,…
1Opinion of the Court
BRUCE, Judge:
Respondent determined deficiencies in petitioner’s income tax as follows:
Tear ending Dec. SI Deficiency
1952_ _$6,455.09
1953-_ 8,970.29
Three issues are presented for decision:(1) Whether certain expenditures in the amount of $37,016.68, made by petitioner during the year 1953 in connection with the preparation and conduct of hearings before the Federal Communications Commission for the purpose of acquiring a television construction permit and ultimately a television license, are deductible as ordinary and necessary business expenses or constituted capital expenditures.(2) If…
2Cases cited28 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Federal Communications Commission v. Sanders Bros. Radio StationSupreme Court of the United States · 1940
- Ashbacker Radio Corp. v. Federal Communications CommissionSupreme Court of the United States · 1946
- Real Estate - Land Title & Trust Co. v. United StatesSupreme Court of the United States · 1940
- Polachek v. CommissionerUnited States Tax Court · 1954
23 more not listed; retrieve them via the Exa API.
3Cited by67 opinions
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Dustin v. CommissionerUnited States Tax Court · 1969
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
- Goodwin v. CommissionerUnited States Tax Court · 1980
62 more not listed; retrieve them via the Exa API.