Legal Opinion

Beck v. Commissioner

United States Tax Court

Decided October 10, 1985No. Docket No. 25003-82PublishedCited by 230 opinions

Petitioner purchased the rights to a book and arranged for independent parties to publish and distribute the book. Held, based on the entire record, petitioner's activity with respect to the book did not constitute an activity engaged in for profit.

1Opinion of the Court

Cohen, Judge:

Respondent determined deficiencies in petitioners’ Federal income tax of $41,293 for 1978 and $17,272 for 1979. After concessions by petitioners, the issues for decision are as follows: (1) Whether petitioner Stanley Beck’s activity in connection with the publication of a certain book constituted an activity engaged in for profit, and (2) if so, whether a nonrecourse promissory note given as part of the consideration for rights to the book was a genuine indebtedness.1 The parties raised various other issues which, in view of our holding herein, we need not and do not address.

FINDI…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Dreicer v. CommissionerUnited States Tax Court · 1982
  3. Engdahl v. CommissionerUnited States Tax Court · 1979
  4. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  5. Brannen v. CommissionerUnited States Tax Court · 1982

17 more not listed; retrieve them via the Exa API.

3Cited by230 opinions

  1. Rose v. CommissionerUnited States Tax Court · 1987
  2. Patin v. CommissionerUnited States Tax Court · 1987
  3. Antonides v. CommissionerUnited States Tax Court · 1988
  4. Hulter v. CommissionerUnited States Tax Court · 1988
  5. Capek v. CommissionerUnited States Tax Court · 1986

225 more not listed; retrieve them via the Exa API.

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