Arlen v. Comm'r
United States Tax Court
Petitioner Harold Arlen is a composer of popular music of modern times. Between 1929 and 1943 he assigned all his right, title, and interest in certain musical compositions to five wholly owned subsidiaries of a parent corporation. Under sec. 24 of title 17 of the United States Code, a copyright could be renewed for an additional term of 28 years by certain persons under certain conditions.
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Petitioner Harold Arlen is a composer of popular music of modern times. Between 1929 and 1943 he assigned all his right, title, and interest in certain musical compositions to five wholly owned subsidiaries of a parent corporation. Under sec. 24 of title 17 of the United States Code, a copyright could be renewed for an additional term of 28 years by certain persons under certain conditions. In March 1959 petitioner and his wife entered into a copyright renewal agreement with the five subsidiaries. Incident to this agreement petitioners also entered into an agreement with the parent company…
1Opinion of the Court
Arundell, Judge:
Respondent determined a deficiency in income tax for the calendar year 1959 in the amount of $41,413.
The only remaining issue is whether an amount of $50,000 received in 1959 by petitioner Harold Arlen, a composer of popular music, from Music Publishers Holding Corp. was received as a bona fide loan or was received as advance royalties.
Other errors were assigned but have been agreed upon. Effect- will be given to these agreements under Rule 50.
FINDINGS OF FACT
¡The stipulated facts are found as stipulated.
Petitioners1 are husband and wife with residence in New York, N. Y., on…
2Cases cited8 opinions
- De Sylva v. BallentineSupreme Court of the United States · 1956
- Fred Fisher Music Co. v. M. Witmark & SonsSupreme Court of the United States · 1943
- Miller Music Corp. v. Charles N. Daniels, Inc.Supreme Court of the United States · 1960
- Graham v. CommissionerUnited States Tax Court · 1984
- Heyn v. CommissionerUnited States Tax Court · 1963
3 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Milenbach v. CommissionerUnited States Tax Court · 1996
- Alexander v. CommissionerUnited States Tax Court · 1973
- Falkoff v. CommissionerUnited States Tax Court · 1974
- John Marascalco, D/B/A Robin Hood Music v. Fantasy, Inc., D/B/A Jondora/parker MusicCourt of Appeals for the Ninth Circuit · 1991
- Frierdich v. CommissionerUnited States Tax Court · 1989
22 more not listed; retrieve them via the Exa API.