Legal Opinion

Chronicle Pub. Co. v. Commissioner

United States Tax Court

Decided October 29, 1991No. Docket No. 18740-90Published

P is the publisher of a daily newspaper. During 1983 and 1984, P claimed a charitable deduction for the contribution of its newspaper clippings library to a sec. 170(c)(2), I.R.C., charitable organization. Held, the newspaper clippings library is property similar to a letter or memorandum which was prepared or produced for P and is excluded from the definition of a capital asset under sec. 1221(3), I.R.C.

1Opinion of the Court

THE CHRONICLE PUBLISHING COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Chronicle Pub. Co. v. Commissioner

Docket No. 18740-90

United States Tax Court

97 T.C. 445; 1991 U.S. Tax Ct. LEXIS 92; 97 T.C. No. 31;

October 29, 1991, Filed

P is the publisher of a daily newspaper. During 1983 and 1984, P claimed a charitable deduction for the contribution of its newspaper clippings library to a sec. 170(c)(2), I.R.C., charitable organization. Held, the newspaper clippings library is property similar to a letter or memorandum which was prepared or produced for P and is…

2Cases cited8 opinions

  1. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  2. Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
  3. Ferrer v. CommissionerUnited States Tax Court · 1961
  4. Estate of Jalkut v. CommissionerUnited States Tax Court · 1991
  5. Chronicle Pub. Co. v. CommissionerUnited States Tax Court · 1991

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