Roosevelt v. Comm'r
United States Tax Court
Held, that $ 18,615.21 which petitioner Franklin D. Roosevelt, Jr., received during the taxable year 1958 as his share of the box office proceeds from a stage play dealing with events in the life of the late President Franklin D. Roosevelt -- which play was written and produced after a certain contract relating to the same had been executed by the author and by said petitioner acting on behalf of himself and certain members of his family -- constitutes gross income to…
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Held, that $ 18,615.21 which petitioner Franklin D. Roosevelt, Jr., received during the taxable year 1958 as his share of the box office proceeds from a stage play dealing with events in the life of the late President Franklin D. Roosevelt -- which play was written and produced after a certain contract relating to the same had been executed by the author and by said petitioner acting on behalf of himself and certain members of his family -- constitutes gross income to petitioner under section 61 of the 1954 Code; and that such amount is not excludable from income under the provisions of…
1Opinion of the Court
Pierce, Judge:
The respondent determined a deficiency in the income tax of the petitioners for their taxable calendar year 1958, in the amount of $88,736.61. The portion of said deficiency here in controversy is approximately $12,647.
The sole issue is whether the sum of $18,615.21 which petitioner, Franklin D. Roosevelt, Jr., received during the taxable year as his share of certain box office proceeds from a stage play entitled “Sunrise at Campobello” (which play was written and produced after a certain contract relating to the same had been executed by the author and by said petitioner acting…
2Cases cited12 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Roberson v. . Rochester Folding Box Co.New York Court of Appeals · 1902
- Sidis v. FR Pub. CorporationCourt of Appeals for the Second Circuit · 1940
- Maurie Starrels and Doris W. Starrels v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Damron v. Doubleday, Doran & Co.New York Supreme Court · 1928
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3Cited by5 opinions
- Lawrence E. Gilbertz and Verna Ann Gilbertz v. United StatesCourt of Appeals for the Tenth Circuit · 1987
- United States v. Dorothy R. GarberCourt of Appeals for the Fifth Circuit · 1979
- Perez v. CommissionerUnited States Tax Court · 2015
- Roosevelt v. Comm'rUnited States Tax Court · 1964
- United States v. Dorothy R. GarberCourt of Appeals for the Fifth Circuit · 1979