Legal Opinion

Westinghouse Broadcasting Co. v. Commissioner

United States Tax Court

Decided August 30, 1961No. Docket No. 78254Published

1. Television network affiliation contract for a term of 2 years, automatically renewable an indefinite number of times unless either party gives written notice of intention not to renew, held to have an indeterminable useful life. Held, further, subsequent termination does not affect status of contract during the taxable years before the Court. 2. Television spot announcement contracts purchased en masse held to have an indeterminable useful life.

1Opinion of the Court

Westinghouse Broadcasting Company, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Westinghouse Broadcasting Co. v. Commissioner

Docket No. 78254

United States Tax Court

36 T.C. 912; 1961 U.S. Tax Ct. LEXIS 88;

August 30, 1961, Filed

Decision will be entered for the respondent.

1. Television network affiliation contract for a term of 2 years, automatically renewable an indefinite number of times unless either party gives written notice of intention not to renew, held to have an indeterminable useful life. Held, further, subsequent termination does not affect status of contract…

2Cases cited35 opinions

  1. Boe v. CommissionerUnited States Tax Court · 1961
  2. Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
  3. Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
  4. Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  5. Bonwit Teller & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931

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