Legal Opinion

Martin v. Commissioner

United States Tax Court

Decided May 21, 1968No. Docket Nos. 5013-64, 5014-64Published

1. Held, that the amount received by a partnership, of which the petitioners were general partners, representing a percentage of the proceeds from the sale by the play authors of the motion-picture rights to the story "The Idyll of Miss Sarah Brown," constituted ordinary business income, rather than capital gain, to the partnership, and hence to the partners. 2. Held, further, that the petitioners' interest in the motion-picture, radio, and television rights in the musical…

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1. Held, that the amount received by a partnership, of which the petitioners were general partners, representing a percentage of the proceeds from the sale by the play authors of the motion-picture rights to the story "The Idyll of Miss Sarah Brown," constituted ordinary business income, rather than capital gain, to the partnership, and hence to the partners. 2. Held, further, that the petitioners' interest in the motion-picture, radio, and television rights in the musical play "The Boy Friend," was a capital asset and and that the gain from the sale thereof constituted long-term capital gain…

1Opinion of the Court

Ernest H. Martin and Nancy G. Martin, Petitioners v. Commissioner of Internal Revenue, Respondent; Cy Feuer and Posy Lee Feuer, Petitioners v. Commissioner of Internal Revenue, Respondent

Martin v. Commissioner

Docket Nos. 5013-64, 5014-64

United States Tax Court

50 T.C. 341; 1968 U.S. Tax Ct. LEXIS 123;

May 21, 1968, Filed

Decisions will be entered under Rule 50.

1. Held, that the amount received by a partnership, of which the petitioners were general partners, representing a percentage of the proceeds from the sale by the play authors of the motion-picture rights to the story "The Idyll of Miss…

Also in this document: Dissent · Raum; Dissent · Fay; Dissent · Tannenwald.

2Cases cited13 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
  3. Commissioner v. BrownSupreme Court of the United States · 1965
  4. Malat v. RiddellSupreme Court of the United States · 1966
  5. Hort v. CommissionerSupreme Court of the United States · 1941

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