Legal Opinion
Lester Wm. Roth and Gertrude F. Roth v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 5, 1963No. 18201, 18208PublishedCited by 26 opinions
1Opinion of the Court
BROWNING, Circuit Judge.
In return for an investment of $1,600, taxpayer’s law firm acquired a 3.2% interest in a partnership organized to produce and exploit motion pictures. The partnership produced one picture— “Knock on Wood,” starring Danny Kaye —and contracted to give Paramount Pictures Corporation exclusive distribution rights to the picture for a ten-year period, which began in July 1954, in return for a portion of the gross receipts.
On August 9, 1954 taxpayer's law firm entered into a written agreement purporting to “sell and assign their entire interest in the partnership” to a…
2Cases cited15 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- 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
- Flora v. United StatesSupreme Court of the United States · 1958
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
10 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Schmitz v. CommissionerUnited States Tax Court · 1968
- Estate of Freeland v. CommissionerCourt of Appeals for the Ninth Circuit · 1968
- Harry C. v. United StatesUnited States Court of Claims · 1967
- Ledoux v. CommissionerUnited States Tax Court · 1981
- Glazer v. CommissionerUnited States Tax Court · 1965
21 more not listed; retrieve them via the Exa API.