Hearst Corp. v. United States

OPINION

BRUGGINK, Judge.

This tax case presents the question of whether plaintiff’s predecessor in interest incurred a loss deductible under Internal Revenue Code (“I.R.C.”) § 1651 with respect to the 1980 taxable year as a result of its termination of the affiliation between television station WDTN and the National Broadcasting Company (“NBC”). Whether Hearst is allowed the deduction depends on the exact nature of the asset in question. If the asset owned in 1976 is the affiliation with NBC per se, then Hearst is entitled to a deduction. There is no question that if the asset is thus…