Legal Opinion

Kwtx Broadcasting Company, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided December 3, 1959No. 17827PublishedCited by 44 opinions

1Per curiam

This petition to review the decision of the Tax Court presents the question whether that court’s finding and conclusion, that the initial outlay made by petitioner in obtaining its three year license to operate a television station cannot be depreciated over the life of the license, under Sec. 167, I.R.C. of 1954, 26 U.S. C.A. § 167, and T.R. Sec. 1.167(a)-3, is clearly erroneous.

The regulation upon which petitioner bases its claim to the right to take depreciation over the life of the license (plus the life of the temporary license) provides :

“If an intangible asset is known from, experience…

2Cases cited2 opinions

  1. Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
  2. KWTX Broadcasting Co. v. CommissionerUnited States Tax Court · 1959

3Cited by44 opinions

  1. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
  2. Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
  3. Dustin v. CommissionerUnited States Tax Court · 1969
  4. Houston Chronicle Publishing Company, Plaintiff-Appellee-Cross v. United States of America, Defendant-Appellant-CrossCourt of Appeals for the Fifth Circuit · 1973
  5. Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961

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