World Publishing Co. v. Commissioner
United States Tax Court
Petitioner in 1950 purchased real estate subject to a lease. The lessee had constructed a building on such property in 1928 under a 50-year lease and in 1950 the remaining useful life of the building was not greater than the unexpired term of the lease.
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Petitioner in 1950 purchased real estate subject to a lease. The lessee had constructed a building on such property in 1928 under a 50-year lease and in 1950 the remaining useful life of the building was not greater than the unexpired term of the lease. In 1952 petitioner paid $ 8,500 in fees to television consultants who prepared all necessary material used by petitioner in an application for a television license in June 1952. The original application was amended in November 1953 and in February 1954. 1. Held, petitioner is not entitled to deductions for depreciation of the…
1Opinion of the Court
MulRoney, Judge:
Respondent determined deficiencies in the petitioner’s income tax for the years 1952, 1953, and 1954 in the amounts of $18,087.04, $14,743.77, and $5,485.91, respectively. The issues are:(1) Whether petitioner is entitled to a deduction for depreciation or amortization of any part of the purchase price of improved real estate which at the time of purchase was subject to a lease held by the lessee who constructed the improvement; and(2) Whether petitioner is entitled to a deduction as an ordinary and necessary expense of fees paid in connection with an application for a…
2Cases cited12 opinions
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Radio Station WBIR, Inc. v. CommissionerUnited States Tax Court · 1959
- Commissioner of Internal Revenue v. Moore. Moore v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- Rowan v. CommissionerUnited States Tax Court · 1954
7 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Bolger v. CommissionerUnited States Tax Court · 1973
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- World Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Midler Court Realty, Inc. v. CommissionerUnited States Tax Court · 1974
- Geneva Drive-In Theatre, Inc. v. CommissionerUnited States Tax Court · 1977
5 more not listed; retrieve them via the Exa API.