Legal Opinion

Tribune Publishing Co. v. Commissioner

United States Tax Court

Decided July 31, 1969No. Docket No. 5477-63Published

Petitioner, owner of an independent television station, was the licensee of various syndicated and feature films. Petitioner wrote off these films under a method which purportedly related payments to usage. Although petitioner filed its returns on an accrual basis, petitioner claimed in each year as the amount of its writeoff with respect to licensed films the same amount as were its payments to licensors during that year. Held, petitioner's method was not proper.

1Opinion of the Court

Tribune Publishing Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Tribune Publishing Co. v. Commissioner

Docket No. 5477-63

United States Tax Court

52 T.C. 717; 1969 U.S. Tax Ct. LEXIS 86;

July 31, 1969, Filed

Decision will be entered under Rule 50.

Petitioner, owner of an independent television station, was the licensee of various syndicated and feature films. Petitioner wrote off these films under a method which purportedly related payments to usage. Although petitioner filed its returns on an accrual basis, petitioner claimed in each year as the amount of its writeoff with…

2Cases cited7 opinions

  1. Commissioner of Internal Revenue v. Philadelphia Transp. Co.Court of Appeals for the Third Circuit · 1949
  2. KIRO, Inc. v. CommissionerUnited States Tax Court · 1968
  3. Early v. CommissionerUnited States Tax Court · 1969
  4. Portland General Electric Company v. United StatesDistrict Court, D. Oregon · 1960
  5. United States v. Portland General Electric Company, an Oregon CorporationCourt of Appeals for the Ninth Circuit · 1962

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