Florida Publishing Co. v. Commissioner
United States Tax Court
Held, no part of the consideration paid to acquire the circulation and all other tangible and intangible assets of a competing newspaper business as a going concern may be currently deducted as an expense of maintaining circulation within the meaning of sec. 173 or under sec. 162. Held, further, since the petitioner did not realize a loss evidenced by a closed or completed transaction or fixed by identifiable events during the taxable year in issue, no part of such purchase…
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Held, no part of the consideration paid to acquire the circulation and all other tangible and intangible assets of a competing newspaper business as a going concern may be currently deducted as an expense of maintaining circulation within the meaning of sec. 173 or under sec. 162. Held, further, since the petitioner did not realize a loss evidenced by a closed or completed transaction or fixed by identifiable events during the taxable year in issue, no part of such purchase price is deductible under sec. 165.
1Opinion of the Court
Goffe, Judge:
The Commissioner determined a $412,304.87 deficiency in petitioner’s Federal income tax for the taxable year 1966. Certain adjustments made in the statutory notice of deficiency were not raised by the petitioner. The only issue before the Court is whether the petitioner may currently deduct under section 173, 165, or 1621 any part of the consideration paid to acquire the circulation and all other tangible and intangible assets of a competing newspaper business as a going concern.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and attached exhibits…
2Cases cited52 opinions
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Lohrke v. CommissionerUnited States Tax Court · 1967
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Booth Newspapers, Inc. v. The United States. The Evening News Association v. The United StatesUnited States Court of Claims · 1962
- Cagle v. CommissionerUnited States Tax Court · 1974
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3Cited by27 opinions
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- UFE, Inc. v. CommissionerUnited States Tax Court · 1989
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