Columbia Broadcasting System, Inc. v. Commissioner
United States Tax Court
Sec. 722(b)(4) -- Commitment -- Radio Station Seeking Better Affiliation. -- The petitioner, owner of radio station KQW, held qualified for relief under the commitment provision of section 722(b)(4) as a result of its actions during the base period in attempting to become the San Francisco Bay area affiliate of CBS, a prominent national network.
1Opinion of the Court
OPINION.
MuRDOCK, Judge:
The Commissioner, hereafter referred to as the respondent, has denied the petitioner relief under section 722(b) (4) for the years 1943 and 1945. The parties presented their evidence before a commissioner designated by this Court, and the findings of that commissioner have been served upon the parties in accordance with the Rules of this Court. The petitioner states in its reply brief, “We are satisfied with the Findings and take no exceptions.” The respondent argues that findings 15, 16, 17, 20, and 22 are immaterial, finding 26 contains an inconsistency, and findings…
2Cases cited7 opinions
- United States v. KalesSupreme Court of the United States · 1941
- Howbert v. PenroseCourt of Appeals for the Tenth Circuit · 1930
- Fezandie & Sperrle v. Comm'rUnited States Tax Court · 1945
- Robinson Terminal Warehouse Corp. v. CommissionerUnited States Tax Court · 1953
- Industrial Yarn Corp. v. CommissionerUnited States Tax Court · 1949
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Schenley Industries, Inc. v. CommissionerUnited States Tax Court · 1964
- Simplicity Mfg. Co. v. CommissionerUnited States Tax Court · 1960
- Columbia Broadcasting System, Inc. v. CommissionerUnited States Tax Court · 1959
- Schenley Industries, Inc. v. CommissionerUnited States Tax Court · 1964
- Thompson v. CommissionerUnited States Tax Court · 1983