Legal Opinion

Peter G. Cranford and Helen Cranford v. The United States

United States Court of Claims

Decided November 13, 1964No. 290-60PublishedCited by 4 opinions

1Opinion of the Court

JONES, Senior Judge.

Plaintiffs 1 seek to recover alleged overpayment of Federal income tax for the year 1955. The single question for our determination involves the right of plaintiff to long term capital gain treatment for a sum of $7,500.

Sometime between 1938 and 1939, plaintiff conceived and invented a format or structure for a radio program. This format was based upon a mathematical formula under which a sponsor would be able to give away an unlimited amount of money, on a progressive basis, to contestants in a quiz show. Briefly, the formula allowed a contestant to parlay and…

2Cases cited4 opinions

  1. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  2. Bowen v. Yankee Network, Inc.District Court, D. Massachusetts · 1942
  3. Stern v. United StatesDistrict Court, E.D. Louisiana · 1958
  4. Regenstein v. CommissionerUnited States Tax Court · 1960

3Cited by4 opinions

  1. Arthur Kurlan and Marilyn Kurlan v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Arthur Kurlan and Marilyn KurlanCourt of Appeals for the Second Circuit · 1965
  2. Bert Crosswhite and Virginia Crosswhite v. The United StatesUnited States Court of Claims · 1966
  3. Forrer v. CommissionerUnited States Tax Court · 1981
  4. Kennedy v. CommissionerUnited States Tax Court · 1965

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