Roy H. Park Broadcasting, Inc. v. Commissioner
United States Tax Court
On Mar. 15, 1962, in a series of transactions qualifying under sec. 334(b)(2), I.R.C. 1954, the stock of a corporation owning television station WNCT-TV was acquired by petitioner and then liquidated, petitioner receiving all the assets of the corporation in liquidation.
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On Mar. 15, 1962, in a series of transactions qualifying under sec. 334(b)(2), I.R.C. 1954, the stock of a corporation owning television station WNCT-TV was acquired by petitioner and then liquidated, petitioner receiving all the assets of the corporation in liquidation. The parties agree that an aggregate basis of $ 695,640 is to be assigned under sec. 334(b)(2) to the entire class of intangibles so acquired, but disagree as to the further allocation of this sum among the various assets which the parties agree comprise this class of assets, namely, network affiliation contracts, FCC license,…
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies in the income taxes of petitioner for the taxable years ending June 30, 1964, and June 30, 1965, in the amounts of $18,089.44 and $17,046.04, respectively. The issues for decision are (1) whether petitioner is entitled to amortization deductions with respect to network affiliation contracts with CBS and ABC and, if so, in what amounts; and (2) whether petitioner sustained a loss upon the termination of the secondary affiliation contract with ABC and, if so, the amount of such loss.
findings of fact
Many of the facts have been stipulated. The…
2Cases cited12 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Etta Potson Bodoglau, Administratrix of the Estate of Michael Potson, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Leonard Refineries, Inc. v. CommissionerUnited States Tax Court · 1948
7 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
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- Forward Communications Corp. v. United StatesUnited States Court of Claims · 1979
- Massey-Ferguson, Inc. v. CommissionerUnited States Tax Court · 1972
- Miami Valley Broadcasting Corp. v. United StatesUnited States Court of Claims · 1974
- Roy H. Park Broadcasting, Inc. v. CommissionerUnited States Tax Court · 1982
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