Legal Opinion

Budget Films, Inc. v. Commissioner

United States Tax Court

Decided July 29, 1985No. Docket No. 7342-81Published

P rented films to the general public. P acquired a film for rental in the United States that was or may have been shown in Mexico. Held, the film is not new sec. 38 property. Fife v. Commissioner, 82 T.C. 1, 15 (1984), followed. P also compiled for rental, reels of film composed of individual film segments previously exhibited publicly, although in a different format.

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P rented films to the general public. P acquired a film for rental in the United States that was or may have been shown in Mexico. Held, the film is not new sec. 38 property. Fife v. Commissioner, 82 T.C. 1, 15 (1984), followed. P also compiled for rental, reels of film composed of individual film segments previously exhibited publicly, although in a different format. The segments (cartoons and short subjects, musical variety entertainment, and other footage) were spliced together and compiled and distributed as packages. Held, these modifications, without more, do not create "reconstructed…

1Opinion of the Court

Budget Films, Inc., a California Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Budget Films, Inc. v. Commissioner

Docket No. 7342-81

United States Tax Court

85 T.C. 114; 1985 U.S. Tax Ct. LEXIS 56; 85 T.C. No. 8;

July 29, 1985, Filed

Decision will be entered under Rule 155.

P rented films to the general public. P acquired a film for rental in the United States that was or may have been shown in Mexico. Held, the film is not new sec. 38 property. Fife v. Commissioner, 82 T.C. 1, 15 (1984), followed.

P also compiled for rental, reels of film composed of individual film…

2Cases cited5 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Fife v. CommissionerUnited States Tax Court · 1984
  3. Goodson-Todman Enterprises, Ltd. v. CommissionerUnited States Tax Court · 1985
  4. Cosby v. United StatesUnited States Court of Claims · 1985
  5. Budget Films, Inc. v. CommissionerUnited States Tax Court · 1985

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