Cory v. Commissioner
United States Tax Court
George Santayana, author of the literary work "Persons and Places," caused the manuscript of that work to be delivered to petitioner, and petitioner, on November 10, 1942, as "Proprietor" of the said work, entered into an agreement for its publication with Charles Scribner's Sons.
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George Santayana, author of the literary work "Persons and Places," caused the manuscript of that work to be delivered to petitioner, and petitioner, on November 10, 1942, as "Proprietor" of the said work, entered into an agreement for its publication with Charles Scribner's Sons. The respondent determined that Santayana made a gift of his entire interest in "Persons and Places" to petitioner and that the proceeds payable by Scribner's to petitioner by reason of its publication of the work were taxable to petitioner as ordinary income. On the facts, held, that (1) Santayana had made a gift of…
1Opinion of the Court
Daniel M. Cory and Margot Cory, Petitioners, v. Commissioner of Internal Revenue, Respondent
Cory v. Commissioner
Docket No. 37209
United States Tax Court
23 T.C. 775; 1955 U.S. Tax Ct. LEXIS 251; 104 U.S.P.Q. (BNA) 209;
January 31, 1955, Filed
Decision will be entered under Rule 50.
George Santayana, author of the literary work "Persons and Places," caused the manuscript of that work to be delivered to petitioner, and petitioner, on November 10, 1942, as "Proprietor" of the said work, entered into an agreement for its publication with Charles Scribner's Sons. The respondent determined that…
2Cases cited23 opinions
- Commissioner of Internal Revenue v. Celanese Corp.Court of Appeals for the D.C. Circuit · 1944
- Rohmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
- Weil v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1936
- Commissioner v. WodehouseSupreme Court of the United States · 1949
- Goldsmith v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
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