Legal Opinion

E. W. Williams Publications, Inc. v. Commissioner

United States Tax Court

Decided November 25, 1955No. Docket No. 48672Published

Petitioner commenced publishing a new trade magazine in 1938 from which it derives advertising and subscription income. Its advertising income for 1945 was abnormal in amount. It claimed relief from excess profits tax under section 721(a)(2)(C), Internal Revenue Code of 1939, on the ground that its advertising income was a separate class of income resulting from research and development of tangible property.

Read the full summary

Petitioner commenced publishing a new trade magazine in 1938 from which it derives advertising and subscription income. Its advertising income for 1945 was abnormal in amount. It claimed relief from excess profits tax under section 721(a)(2)(C), Internal Revenue Code of 1939, on the ground that its advertising income was a separate class of income resulting from research and development of tangible property. Held: Assuming that petitioner had a class of income as described in section 721(a)(2)(C) and that petitioner established the amount of net abnormal income derived therefrom, petitioner…

1Opinion of the Court

E. W. Williams Publications, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

E. W. Williams Publications, Inc. v. Commissioner

Docket No. 48672

United States Tax Court

25 T.C. 282; 1955 U.S. Tax Ct. LEXIS 43;

November 25, 1955, Filed

Decision will be entered for the respondent.

Petitioner commenced publishing a new trade magazine in 1938 from which it derives advertising and subscription income. Its advertising income for 1945 was abnormal in amount. It claimed relief from excess profits tax under section 721(a)(2)(C), Internal Revenue Code of 1939, on the ground that its…

2Cases cited10 opinions

  1. Geyer, Cornell & Newell, Inc. v. CommissionerUnited States Tax Court · 1946
  2. W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
  3. Soabar Co. v. CommissionerUnited States Tax Court · 1946
  4. Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
  5. Producers Crop Improv. Asso. v. CommissionerUnited States Tax Court · 1946

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API