Hill v. Commissioner
United States Tax Court
Petitioner was employed as a writer-producer by KTTV at an agreed salary and an agreement that in addition to this salary he was to have a 5-percent interest in certain receipts from TV programs to which he was assigned. KTTV sold a series which had been written and produced by petitioner and paid petitioner 5 percent of its net profit from the sale.
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Petitioner was employed as a writer-producer by KTTV at an agreed salary and an agreement that in addition to this salary he was to have a 5-percent interest in certain receipts from TV programs to which he was assigned. KTTV sold a series which had been written and produced by petitioner and paid petitioner 5 percent of its net profit from the sale. Held, the amount received by petitioner from KTTV representing 5 percent of that company's net profit from the sale of the TV series was ordinary income and not capital gain.
1Opinion of the Court
Jackson Hill and Irene Hill, Petitioners v. Commissioner of Internal Revenue, Respondent
Hill v. Commissioner
Docket No. 1179-65
United States Tax Court
47 T.C. 613; 1967 U.S. Tax Ct. LEXIS 134; 153 U.S.P.Q. (BNA) 757;
March 23, 1967, Filed
Decision will be entered for respondent.
Petitioner was employed as a writer-producer by KTTV at an agreed salary and an agreement that in addition to this salary he was to have a 5-percent interest in certain receipts from TV programs to which he was assigned. KTTV sold a series which had been written and produced by petitioner and paid petitioner 5 percent of…
2Cases cited7 opinions
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Nat Holt and Blanche Holt, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Lehman v. CommissionerUnited States Tax Court · 1951
- Holt v. CommissionerUnited States Tax Court · 1961
- Arthur Kurlan and Marilyn Kurlan v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Arthur Kurlan and Marilyn KurlanCourt of Appeals for the Second Circuit · 1965
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