Publishers New Press, Inc. v. Commissioner
United States Tax Court
1. Petitioner solicited funds in its newspaper for the purpose of meeting its operating expenses and to keep the newspaper in operation.
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1. Petitioner solicited funds in its newspaper for the purpose of meeting its operating expenses and to keep the newspaper in operation. Held, the contributions received by petitioner in response to such solicitations were includable in gross income under section 22(a), I.R.C. 1939, and were not excludable from income as gifts within the meaning of section 22(b)(3), I.R.C. 1939. 2. Held, further, petitioner correctly reported its receipts from "bundle sales." 3. Held, further, petitioner failed to prove it was entitled to a bad debt deduction in 1952.
1Opinion of the Court
Mulronex, Judge:
The respondent determined deficiencies in the petitioner’s income tax for 1951, 1952, and 1953 in the respective amounts of $5,469.57, $30,268.55, and $3,129.58. The issues are (1) whether the amounts of $28,800.04, $158,870, and $153,789.60 received by petitioner in the years 1951,1952, and 1953, respectively, are includable in its taxable income for those years; (2) whether petitioner failed to report taxable income from newspaper sales in the years 1951, 1952, and 1953 in the amounts of $7,162.56, $30,176.38, and $29,206.66, respectively; and (3) whether petitioner is…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Teleservice Company of Wyoming Valley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Poorman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1942
6 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Fountain v. CommissionerUnited States Tax Court · 1973
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Marquis v. CommissionerUnited States Tax Court · 1968
- Cimarron Trust Estate v. CommissionerUnited States Tax Court · 1972
- Hagar v. CommissionerUnited States Tax Court · 1965
8 more not listed; retrieve them via the Exa API.