Legal Opinion

Radio Station WBIR, Inc. v. Commissioner

United States Tax Court

Decided January 23, 1959No. Docket No. 60621PublishedCited by 67 opinions

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

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Federal Communications Commission v. Sanders Bros. Radio StationSupreme Court of the United States · 1940
  3. Ashbacker Radio Corp. v. Federal Communications CommissionSupreme Court of the United States · 1946
  4. Real Estate - Land Title & Trust Co. v. United StatesSupreme Court of the United States · 1940
  5. Polachek v. CommissionerUnited States Tax Court · 1954

23 more not listed; retrieve them via the Exa API.

3Cited by67 opinions

  1. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
  2. Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
  3. Dustin v. CommissionerUnited States Tax Court · 1969
  4. Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
  5. Goodwin v. CommissionerUnited States Tax Court · 1980

62 more not listed; retrieve them via the Exa API.

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