Roth v. Commissioner
United States Tax Court
Held, amounts received by petitioners during 1955 and 1956 representing a percentage of the gross receipts from the distribution of a motion picture constitute ordinary income.
1Opinion of the Court
Withey, Judge:
Respondent has determined deficiencies in the income tax of petitioners as follows:
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The sole issue to be decided is whether amounts received by petitioners in 1955 and 1956 representing a percentage of the gross receipts from the distribution of a motion picture constitute ordinary income or capital gain.
FINDINGS OF FACT.
The agreed facts are found as stipulated.
Petitioners, Lester William Noth and Gertrude F. Noth, husband and wife and residents of California, filed joint income tax returns for the calendar years 1955 and 1956 with the director of internal revenue…
2Cases cited3 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- James M. Tunnell, Jr., and Mildred S. Tunnell v. United StatesCourt of Appeals for the Third Circuit · 1958
- Paul W. Trousdale v. Commissioner of Internal Revenue, Marguerite R. Trousdale v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
3Cited by18 opinions
- Schmitz v. CommissionerUnited States Tax Court · 1968
- Lester Wm. Roth and Gertrude F. Roth v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Ledoux v. CommissionerUnited States Tax Court · 1981
- Glazer v. CommissionerUnited States Tax Court · 1965
- Holman v. CommissionerUnited States Tax Court · 1976
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