Gulf Tel. Corp. v. Commissioner
United States Tax Court
In 1956 petitioner purchased a television station for $ 4,800,000 of which $ 2,700,000 was allocated by petitioner to the purchase price of a network affiliation contract which the station had with CBS. This contract like all network affiliation contracts was for 2 years (the maximum period permitted by the FCC) but was automatically renewable for successive 2-year terms unless either party gave 6 months' written notice of intention not to renew.
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In 1956 petitioner purchased a television station for $ 4,800,000 of which $ 2,700,000 was allocated by petitioner to the purchase price of a network affiliation contract which the station had with CBS. This contract like all network affiliation contracts was for 2 years (the maximum period permitted by the FCC) but was automatically renewable for successive 2-year terms unless either party gave 6 months' written notice of intention not to renew. At the time it was acquired by petitioner at an allocated cost of $ 2,700,000, 19 months of a 2-year term had yet to run. The contract was still in…
1Opinion of the Court
Gulf Television Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Gulf Tel. Corp. v. Commissioner
Docket No. 3348-66
United States Tax Court
52 T.C. 1038; 1969 U.S. Tax Ct. LEXIS 54;
September 25, 1969, Filed
Decision will be entered for the respondent.
In 1956 petitioner purchased a television station for $ 4,800,000 of which $ 2,700,000 was allocated by petitioner to the purchase price of a network affiliation contract which the station had with CBS. This contract like all network affiliation contracts was for 2 years (the maximum period permitted by the FCC) but was…
Also in this document: Concurrence · Dawson; Concurrence · Tannenwald.
2Cases cited28 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
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