Carnegie Productions, Inc. v. Commissioner
United States Tax Court
Petitioner produced a motion-picture film with funds supplied by another corporation pursuant to an agreement whereby upon completion of the motion picture all rights thereto, except petitioner's share in any income from its distribution, vested in the corporation supplying the funds. Held, petitioner acquired no basis or interest in the motion picture on account of which petitioner could claim a deduction for amortization or depreciation.
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Petitioner produced a motion-picture film with funds supplied by another corporation pursuant to an agreement whereby upon completion of the motion picture all rights thereto, except petitioner's share in any income from its distribution, vested in the corporation supplying the funds. Held, petitioner acquired no basis or interest in the motion picture on account of which petitioner could claim a deduction for amortization or depreciation. Held, further: Petitioner is not entitled to a deduction for interest. No liability for interest has accrued and no indebtedness has been established.…
1Opinion of the Court
Carnegie Productions, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Carnegie Productions, Inc. v. Commissioner
Docket No. 1914-68
United States Tax Court
59 T.C. 642; 1973 U.S. Tax Ct. LEXIS 177; 59 T.C. No. 63;
February 5, 1973, Filed
Decision will be entered for the respondent.
Petitioner produced a motion-picture film with funds supplied by another corporation pursuant to an agreement whereby upon completion of the motion picture all rights thereto, except petitioner's share in any income from its distribution, vested in the corporation supplying the funds. Held, petitioner…
Also in this document: Concurrence.
2Cases cited19 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Miller Music Corp. v. Charles N. Daniels, Inc.Supreme Court of the United States · 1960
- Edward B. Marks Music Corporation, Plaintiff-Appellant-Appellee v. Charles K. Harris Music Publishing Co., Inc., Defendant-Appellee-AppellantCourt of Appeals for the Second Circuit · 1958
- G. Ricordi & Co. v. Paramount Pictures, Inc.Court of Appeals for the Second Circuit · 1951
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