WHEC, Inc. v. Commissioner
United States Tax Court
Certain expenditures made by petitioner in 1956 in perfecting the grant in 1953 of a construction permit for a television station, which grant had been made without a hearing and as such was subject to protest and was in fact protested, held, to be capital expenditures and not deductible in 1956 as ordinary and necessary expenses under section 162(a), I.R.C. 1954.
1Opinion of the Court
OPINION.
Arundell, Judge:
Respondent determined a deficiency in income tax for the calendar year 1956 in the amount of $16,285.45.
The only error assigned is as follows:(1) The Commissioner erroneously disallowed the deduction of $31,318.17 as ordinary and necessary business expense paid or incurred in 1956 by petitioner; the petitioner, having obtained a construction permit for a television station in March, 1953 and having operated a television station since November, 1953, protected its right to continue in business and defended its business interests against attack in 1956 proceedings before…
2Cases cited8 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Radio Station WBIR, Inc. v. CommissionerUnited States Tax Court · 1959
- Kwtx Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- KWTX Broadcasting Co. v. CommissionerUnited States Tax Court · 1959
- Federal Broadcasting System, Inc. v. Federal Communications Commission, Whec, Inc., Intervenor, Veterans Broadcasting Company, Inc., IntervenorCourt of Appeals for the D.C. Circuit · 1955
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3Cited by5 opinions
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Ncnb Corporation, a North Carolina Corporation North Carolina National Bank v. United StatesCourt of Appeals for the Fourth Circuit · 1982
- Intervest Enterprises, Inc. v. CommissionerUnited States Tax Court · 1971
- Ncnb Corporation, a North Carolina Corporation North Carolina National Bank v. United StatesCourt of Appeals for the Fourth Circuit · 1982
- WHEC, Inc. v. CommissionerUnited States Tax Court · 1962