KIRO, Inc. v. Commissioner
United States Tax Court
Prior to 1958, petitioner's predecessor, Queen City Broadcasting Co., had operated a radiobroadcasting station in Seattle, Wash. In February 1958, it began televising programs on channel 7 in that area. In 1958, it, as licensee, entered into 41 contracts with licensors for films to be telecast at a total cost of $ 1,196,319.90. On its corporation income tax return for 1958, it claimed $ 424,158.87 as a deduction under a sliding-scale method for "Film rentals and purchases."
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Prior to 1958, petitioner's predecessor, Queen City Broadcasting Co., had operated a radiobroadcasting station in Seattle, Wash. In February 1958, it began televising programs on channel 7 in that area. In 1958, it, as licensee, entered into 41 contracts with licensors for films to be telecast at a total cost of $ 1,196,319.90. On its corporation income tax return for 1958, it claimed $ 424,158.87 as a deduction under a sliding-scale method for "Film rentals and purchases." Respondent disallowed $ 245,506.71 of the deduction so claimed on the ground that the total costs of the television…
1Opinion of the Court
Bruce, Judge:
Respondent determined deficiencies in income tax for the calendar years 1955, 1956, 1957, and 1958 in the amounts of $11,876.78, $72,864.19, $31,888.20, and none, respectively.
Several issues have either been settled or withdrawn, and certain additional deductions conceded in the stipulations of facts, effect to all of which will be given in the computations to be made under Rule 50.
Two issues remain to be decided as follows:(1) Whether the respondent erred in disallowing $245,506.71 of the $424,158.87 deducted for “Film rentals and purchases” claimed as a part of the cost of…
2Cases cited13 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Burnet v. HoustonSupreme Court of the United States · 1931
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Simms v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1952
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
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3Cited by27 opinions
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- Citizens & Southern Corp. v. CommissionerUnited States Tax Court · 1988
- Schneider v. CommissionerUnited States Tax Court · 1975
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