Appeal of the Danville Press, Inc.

Board of Tax Appeals

Appeal of the Danville Press, Inc.

1 B.T.A. 1171

CourtUnited States Board of Tax Appeals

DecidedMay 21, 1925

DocketDocket No. 900

StatusPublished

Cited by19 cases

This text of 1 B.T.A. 1171 (Appeal of the Danville Press, Inc.) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of the Danville Press, Inc., 1 B.T.A. 1171 (bta 1925).

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Opinion

OPINION.

Phillips :

The taxpajwr claims the right to deduct in 1920 depreciation in the sum of $30,000, representing ten-twelfths of $36,000 paid by it for 9,000 subscriptions obtained upon and as a part of the purchase by it of all the assets of a corporation publishing a daily newspaper. The taxpayer urges that, as all of these subscriptions expired within a period of 12 months, it is entitled to write off within that period the total amount paid for such subscriptions. This necessarily involves the proposition that at the end of such period the subscription list purchased by it had no value. We can not agree that this is so, nor can we agree that what the taxpayer purchased was 9,000 contracts expiring within 12 months. It purchased an asset which was a subscription list subject to fluctuations from time to time.

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OPINION.

Phillips :

The taxpajwr claims the right to deduct in 1920 depreciation in the sum of $30,000, representing ten-twelfths of $36,000 paid by it for 9,000 subscriptions obtained upon and as a part of the purchase by it of all the assets of a corporation publishing a daily newspaper. The taxpayer urges that, as all of these subscriptions expired within a period of 12 months, it is entitled to write off within that period the total amount paid for such subscriptions. This necessarily involves the proposition that at the end of such period the subscription list purchased by it had no value. We can not agree that this is so, nor can we agree that what the taxpayer purchased was 9,000 contracts expiring within 12 months. It purchased an asset which was a subscription list subject to fluctuations from time to time.

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Bluebook (online)

1 B.T.A. 1171, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-the-danville-press-inc-bta-1925.

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