Jefferson-Pilot Corporation and Subsidiaries v. Commissioner of Internal Revenue

OPINION

BUTZNER, Senior Circuit Judge:

The principal question in this petition for review is whether the taxpayer, Jefferson-Pilot Corporation, can amortize the costs of acquiring Federal Communication Commission (FCC) broadcast licenses. The answer depends on whether an FCC license is a “franchise” within the meaning of § 1253 of the Internal Revenue Code, 26 U.S.C. § 1253. The Commissioner of Internal Revenue appeals the Tax Court’s decision holding that three radio broadcasting licenses transferred to the taxpayer’s subsidiary, Jefferson-Pilot Communications Co., are public franchises.…