Westinghouse Broadcasting Co. v. Commissioner
United States Tax Court
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
Train, Judge;
Respondent determined deficiencies in petitioner’s income tax for the years 1953 and 1954 in the amounts of $363,371.93 and $622,410.13, respectively. Petitioner seeks a determination that it made overpayments of its income tax for those years by reason of additional depreciation of its cost of the affiliation contract and spot advertising contracts which petitioner failed to claim in its returns.
The issues presented are:(1) Whether petitioner is entitled to depreciation deductions with respect to its purchase price of a network affiliation contract for a specific term but…
2Cases cited34 opinions
- Boe v. CommissionerUnited States Tax Court · 1961
- Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Bonwit Teller & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931
- Thrifticheck Service Corp. v. CommissionerUnited States Tax Court · 1960
29 more not listed; retrieve them via the Exa API.
3Cited by72 opinions
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Richardson v. CommissionerUnited States Tax Court · 1979
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Forward Communications Corp. v. United StatesUnited States Court of Claims · 1979
- Commissioner of Internal Revenue v. Indiana Broadcasting CorporationCourt of Appeals for the Seventh Circuit · 1965
67 more not listed; retrieve them via the Exa API.