Legal Opinion

General Communication Co. v. Commissioner

United States Tax Court

Decided January 8, 1960No. Docket No. 67528Published

Held, petitioner's alleged liability to R.C.A. under a patent-licensing agreement was neither uncontested nor sufficiently fixed as of the end of the taxable year (Sept. 30, 1954) to justify accrual thereof.

1Opinion of the Court

General Communication Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

General Communication Co. v. Commissioner

Docket No. 67528

United States Tax Court

33 T.C. 640; 1960 U.S. Tax Ct. LEXIS 233;

January 8, 1960, Filed

Decision will be entered for the respondent.

Held, petitioner's alleged liability to R.C.A. under a patent-licensing agreement was neither uncontested nor sufficiently fixed as of the end of the taxable year (Sept. 30, 1954) to justify accrual thereof.

Bertram H. Loewenberg, Esq., and Robert S. Jones, Esq., for the petitioner.

Chester M. Howe, Esq., for the…

2Cases cited7 opinions

  1. Lucas v. American Code Co.Supreme Court of the United States · 1930
  2. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  3. Scott Paper Co. v. Marcalus Manufacturing Co.Supreme Court of the United States · 1945
  4. Producers' Fuel Co. v. CommissionerUnited States Board of Tax Appeals · 1924
  5. Bump Confectionery Co. v. CommissionerUnited States Board of Tax Appeals · 1926

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