GENERAL COMMUNICATION CO. v. COMMISSIONER

Docket No. 67528.

33 T.C. 640 (1960)

GENERAL COMMUNICATION COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 8, 1960.


Attorney(s) appearing for the Case

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

Chester M. Howe, Esq., for the respondent.


The only issue presently in dispute, arising out of respondent's determination of a $48,762.07 deficiency in petitioner's income and excess profits tax for the taxable year ended September 30, 1954, is whether petitioner was entitled to accrue a $75,000 deduction for that year with respect to royalties allegedly due and owing Radio Corporation of America under a patent license agreement.

FINDINGS OF FACT.

Certain facts have been stipulated and are incorporated...

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