Legal Opinion

Griffin v. Commissioner

United States Tax Court

Decided December 31, 1959No. Docket No. 65139Published

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.

Read the full summary

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

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. Snell v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1938
  3. MacMurray v. CommissionerUnited States Tax Court · 1953
  4. Griffin v. CommissionerUnited States Tax Court · 1959

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API