Griffin v. Commissioner
United States Tax Court
In 1950, petitioner purchased a one-half interest in a story, which was to be transferred at cost to an independent motion picture producing corporation, petitioner to act as producer. The other one-half owner withdrew, and in 1951 petitioner sold the story to a major studio, being concurrently hired as producer. He had previously consummated two similar transactions.
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In 1950, petitioner purchased a one-half interest in a story, which was to be transferred at cost to an independent motion picture producing corporation, petitioner to act as producer. The other one-half owner withdrew, and in 1951 petitioner sold the story to a major studio, being concurrently hired as producer. He had previously consummated two similar transactions. He never produced a story he did not first sell, and only under unusual circumstances ever sold a story he was not also hired to produce or coproduce. Held: Petitioner was by trade or business a motion picture producer. The 1951…
1Opinion of the Court
Z. Wayne Griffin and Elinor W. Griffin, Petitioners, v. Commissioner of Internal Revenue, Respondent
Griffin v. Commissioner
Docket No. 65139
United States Tax Court
33 T.C. 616; 1959 U.S. Tax Ct. LEXIS 1;
December 31, 1959, Filed
Decision will be entered for the respondent.
In 1950, petitioner purchased a one-half interest in a story, which was to be transferred at cost to an independent motion picture producing corporation, petitioner to act as producer. The other one-half owner withdrew, and in 1951 petitioner sold the story to a major studio, being concurrently hired as producer. He had…
2Cases cited4 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Snell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1938
- MacMurray v. CommissionerUnited States Tax Court · 1953
- Griffin v. CommissionerUnited States Tax Court · 1959