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GENERAL ARTISTS CORP. v. COMMISSIONER OF INTERNAL REV.

No. 209, Docket 22562.

205 F.2d 360 (1953)

GENERAL ARTISTS CORP. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Second Circuit.

Decided June 18, 1953.

Attorney(s) appearing for the Case

Miller & Miller, Bernard L. Miller and Morton Miller, New York City (Harry J. Winick and Morton Miller, New York City, of counsel), for petitioner.

H. Brian Holland, Ellis N. Slack, A. F. Prescott and Morton K. Rothschild, Washington, D. C., for respondent.

Before SWAN, Chief Judge, and AUGUSTUS N. HAND and FRANK, Circuit Judges.

FRANK, Circuit Judge.

As the facts are stated in the opinion of the Tax Court, 17 T.C. 1517, we shall only briefly review them here:

Taxpayer had contracts with a popular singer (through managing agents representing him) by which it was his exclusive booking-agent and entitled to receive 10% of his earnings from such bookings. In December 1943, it purported to sell these contracts to MCA Artists, Ltd., another booking agent...

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