Miller v. Comm'r
United States Tax Court
Petitioner is the widow of a well-known band leader, who died in 1944. In 1952 she executed an agreement with Universal Pictures relating to the production of one or more motion pictures based upon his life, in which she and other members of the family would also be portrayed. She agreed to use her best efforts to obtain certain consents or releases from other members of the family.
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Petitioner is the widow of a well-known band leader, who died in 1944. In 1952 she executed an agreement with Universal Pictures relating to the production of one or more motion pictures based upon his life, in which she and other members of the family would also be portrayed. She agreed to use her best efforts to obtain certain consents or releases from other members of the family. Pursuant to Universal's undertaking to pay petitioner certain percentages of the gross proceeds from any such motion picture, petitioner in 1954 received $ 409,336.34. Held: The consideration thus received was…
1Opinion of the Court
Helen D. Miller, Petitioner, v. Commissioner of Internal Revenue, Respondent
Miller v. Comm'r
Docket No. 71569
United States Tax Court
35 T.C. 631; 1961 U.S. Tax Ct. LEXIS 241;
January 26, 1961, Filed
Decision will be entered under Rule 50.
Petitioner is the widow of a well-known band leader, who died in 1944. In 1952 she executed an agreement with Universal Pictures relating to the production of one or more motion pictures based upon his life, in which she and other members of the family would also be portrayed. She agreed to use her best efforts to obtain certain consents or releases from other…
2Cases cited27 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Sidis v. FR Pub. CorporationCourt of Appeals for the Second Circuit · 1940
- Gautier v. Pro-Football, Inc.New York Court of Appeals · 1952
- Haelan Laboratories, Inc. v. Topps Chewing Gum, Inc.Court of Appeals for the Second Circuit · 1953
- Uproar Co. v. National Broadcasting Co.Court of Appeals for the First Circuit · 1936
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