General Artists Corp. v. Commissioner of Internal Revenue

FRANK, Circuit Judge.

■As the facts are stated in the opinion of the Tax Court, 17 T.C. 1517, we shall only briefly review’them here:

Taxpayer had contracts with a popular singer (through managing agents represent; ing him) by which it was his exclusive booking-agent and entitled to receive 10% of his earnings from such bookings. In December 1943, it purported to sell these contracts to MCA -Artists, Ltd., another booking agent, which we shall call “MCA.” The agreement between taxpayer and MCA provided that, after the assignment of contracts, they should be cancelled and MCA should make new…