Teleservice Co. of Wyoming Valley v. Commissioner
United States Tax Court
The taxpayer corporation promoted, constructed, and now operates a community television antenna system in Wilkes-Barre and Kingston, Pennsylvania. To help finance construction of the system, contributions were solicited from prospective customers. A contribution was a prerequisite to use of the system. It alone however did not entitle the contributor to receive television signals. The contributor also had to make monthly payments, in advance, in order to receive the signals.
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The taxpayer corporation promoted, constructed, and now operates a community television antenna system in Wilkes-Barre and Kingston, Pennsylvania. To help finance construction of the system, contributions were solicited from prospective customers. A contribution was a prerequisite to use of the system. It alone however did not entitle the contributor to receive television signals. The contributor also had to make monthly payments, in advance, in order to receive the signals. A contributor could not sell, assign, or transfer his eligibility to receive television signals, but he remained…
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined the following deficiencies in the petitioner’s income taxes:
Year ended January SI Deficiency
1952- $3,210.83
1953- 13,013.09
Certain adjustments made by the Commissioner were not contested. The only issue presented in this case is whether “contributions” by subscribers to the petitioner’s community antenna television system constitute gross income within the meaning of section 22 (a) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
Some of the facts are stipulated. Those facts and the stipulated exhibits are found as stipulated and are…
2Cases cited7 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Edwards v. Cuba RailroadSupreme Court of the United States · 1925
- General American Investors Co. v. CommissionerSupreme Court of the United States · 1955
- Great Northern Ry. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1930
2 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Denver & R. G. W. R. Co. v. CommissionerUnited States Tax Court · 1959
- Teleservice Company of Wyoming Valley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Kansas City S. Indus. v. CommissionerUnited States Tax Court · 1992
- Alsop v. CommissionerUnited States Tax Court · 1960
- Swenson v. CommissionerUnited States Tax Court · 1965
23 more not listed; retrieve them via the Exa API.