Legal Opinion

Coca-Cola Bottling Co. v. Commissioner

United States Board of Tax Appeals

Decided May 13, 1927No. Docket No. 9387PublishedCited by 19 opinions

No allowance can be made for the exhaustion of the cost of a contract granting a perpetual privilege to bottle Coca-Cola.

1Opinion of the Court

*1334OPINION.

Littleton:

Section 234 (a) (7) of the Revenue Acts of 1918 and 1921 allows as a deduction a reasonable allowance for the exhaustion, wear and tear of property used in the trade or business, including a reasonable allowance for obsolescence.

It is insisted by petitioner that Coca-Cola contracts of the character as the one owned by it are estimated by persons when purchasing them to produce a return sufficient to restore the capital invested therein within six or seven years, and that the investment of $83,877.02 in the • contract here involved was made with the expectation that such…

2Cited by19 opinions

  1. Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
  2. Radio Station WBIR, Inc. v. CommissionerUnited States Tax Court · 1959
  3. Commissioner of Internal Revenue v. Indiana Broadcasting CorporationCourt of Appeals for the Seventh Circuit · 1965
  4. Indiana Broadcasting Corp. v. CommissionerUnited States Tax Court · 1964
  5. Rudie v. CommissionerUnited States Tax Court · 1967

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