General Artists Corp. v. Commissioner
United States Tax Court
Capital Assets -- Personal Service Contract -- Section 117 (a) (1). -- Amounts received from alleged purchaser of contracts for personal services were not capital gains.
1Opinion of the Court
General Artists Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
General Artists Corp. v. Commissioner
Docket No. 25416
United States Tax Court
17 T.C. 1517; 1952 U.S. Tax Ct. LEXIS 248;
March 18, 1952, Promulgated
Decision will be entered under Rule 50.
Capital Assets -- Personal Service Contract -- Section 117 (a) (1). -- Amounts received from alleged purchaser of contracts for personal services were not capital gains.
Morton Miller, Esq., and Nathaniel Miller, C. P. A., for the petitioner.
William A. Schmitt, Esq., for the respondent.
Murdock, Judge. Kern, J., concurs in the…
Also in this document: Dissent.
2Cases cited8 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. EubankSupreme Court of the United States · 1941
- Arkansas Valley Smelting Co. v. Belden Mining Co.Supreme Court of the United States · 1888
- Jones, Collector of Internal Revenue v. CorbynCourt of Appeals for the Tenth Circuit · 1950
- BEALS'ESTATE v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1936
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