Calypso Music, Inc. v. Commissioner
United States Tax Court
P was incorporated by K. K is a motion picture music editor and P's sole shareholder, director, and officer. P contracted with motion picture studios for K's services as a music editor. Each of the contracts was memorialized, in part, by a "loan-out agreement" or a "deal memorandum". Each contract made specific reference to the services of K. R determined P was a personal holding company as defined in sec. 542 I.R.C. for its 1996 and 1997 taxable years.
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P was incorporated by K. K is a motion picture music editor and P's sole shareholder, director, and officer. P contracted with motion picture studios for K's services as a music editor. Each of the contracts was memorialized, in part, by a "loan-out agreement" or a "deal memorandum". Each contract made specific reference to the services of K. R determined P was a personal holding company as defined in sec. 542 I.R.C. for its 1996 and 1997 taxable years. R also determined that P was liable for accuracy related penalties under sec. 6662(a) I.R.C.. HELD: P was a personal holding company for its…
1Opinion of the Court
CALYPSO MUSIC INCORPORATED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Calypso Music, Inc. v. Commissioner
No. 12683-99
United States Tax Court
T.C. Memo 2000-293; 2000 Tax Ct. Memo LEXIS 344; 80 T.C.M. (CCH) 388; T.C.M. (RIA) 54048;
September 20, 2000, Filed
Decision will be entered under Rule 155.
P was incorporated by K. K is a motion picture music editor
and P's sole shareholder, director, and officer. P contracted
with motion picture studios for K's services as a music editor.
Each of the contracts was memorialized, in part, by a "loan-out
agreement" or a "deal memorandum". Each…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. BoyleSupreme Court of the United States · 1985
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Fulman v. United StatesSupreme Court of the United States · 1978
- Ewing v. CommissionerUnited States Tax Court · 1988
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