Caldwell-Clements, Inc. v. Commissioner
United States Tax Court
The petitioner commenced planning and prepublication activity on a trade magazine in 1935 dealing with electronics but, due to the activities of a competitor, it was unable to commence publication until November 1942 when the magazine scored an immediate financial success.
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The petitioner commenced planning and prepublication activity on a trade magazine in 1935 dealing with electronics but, due to the activities of a competitor, it was unable to commence publication until November 1942 when the magazine scored an immediate financial success. Held, relief under section 721, I. R. C. 1939, denied for 1943 because, even assuming arguendo that it in all other respects qualified therefor, the petitioner failed to establish the cost of research or development of the magazine in each of the prior years, making it impossible to compute the amount of any net abnormal…
1Opinion of the Court
OPINION.
Kern, Judge:
The petitioner was organized July 13, 1935, by two former editorial employees of McGraw-Hill Publishing Company, Inc., who had worked together for many years in that company as publisher and as editor of technical magazines dealing with the fields of radio and electronics. The petitioner was able to commence publication in September 1935 of a magazine, Eadio Today, designed for radio sales and service dealers, and also to commence planning and other preparatory work toward the publication of a technical magazine intended for a highly selective audience of top level…
2Cases cited5 opinions
- W. B. Knight Machinery Co. v. CommissionerUnited States Tax Court · 1946
- Ramsey Accessories Mfg. Corp. v. CommissionerUnited States Tax Court · 1948
- Pabst Air Conditioning Corp. v. CommissionerUnited States Tax Court · 1950
- Crowell-Collier Pub. Co. v. CommissionerUnited States Tax Court · 1956
- Atlumor Mfg. Co. v. CommissionerUnited States Tax Court · 1949
3Cited by3 opinions
- White v. CommissionerUnited States Tax Court · 1957
- Caldwell-Clements, Inc. v. CommissionerUnited States Tax Court · 1957
- White v. CommissionerUnited States Tax Court · 1957