Holt v. Commissioner
United States Tax Court
1. Nat Holt (and his partnership) entered into two agreements with Paramount Pictures Corporation to produce 11 motion pictures for Paramount. Holt was to receive a fixed producer's fee of $ 15,000 or $ 20,000 for each picture produced and a 25 per cent participating interest in the excess gross receipts of the pictures over and above specified multiples of production and distribution costs.
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1. Nat Holt (and his partnership) entered into two agreements with Paramount Pictures Corporation to produce 11 motion pictures for Paramount. Holt was to receive a fixed producer's fee of $ 15,000 or $ 20,000 for each picture produced and a 25 per cent participating interest in the excess gross receipts of the pictures over and above specified multiples of production and distribution costs. After 9 of the 11 pictures had been produced, Holt and Paramount entered into an agreement terminating the two production agreements whereunder Paramount paid to Holt $ 153,000 and Holt released Paramount…
1Opinion of the Court
DebNNEN, Judge:
Respondent determined deficiencies in petitioners’ income tax for tbe years 1953, 1954, and 1955 in tbe amounts of $1,567.96, $18,919.91, and $6,936.90, respectively. Petitioners signed a consent for tbe assessment and collection of $1,511.63 of tbe tax deficiency for tbe year 1955.
Tbe primary issue is whether amounts received by petitioners from Paramount Pictures Corporation upon termination of two agreements, under which petitioner Nat Holt agreed to produce certain motion pictures for Paramount in consideration of a fixed producer’s fee plus a participating interest in the…
2Cases cited6 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Helvering v. SmithCourt of Appeals for the Second Circuit · 1937
- Shuster v. HelveringCourt of Appeals for the Second Circuit · 1941
1 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Luna v. CommissionerUnited States Tax Court · 1964
- Diamond v. CommissionerUnited States Tax Court · 1971
- Ferrer v. CommissionerUnited States Tax Court · 1961
- Nat Holt and Blanche Holt, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Kingsbury v. CommissionerUnited States Tax Court · 1976
26 more not listed; retrieve them via the Exa API.