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
Caldwell-Clements, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Caldwell-Clements, Inc. v. Commissioner
Docket No. 51570
United States Tax Court
27 T.C. 691; 1957 U.S. Tax Ct. LEXIS 280;
January 22, 1957, Filed
Decision will be entered for the respondent.
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…
2Cases cited6 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
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