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LITVAK v. COMMISSIONER

Docket No. 31244.

23 T.C. 441 (1954)

ANATOLE LITVAK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 7, 1954.

Attorney(s) appearing for the Case

Adam Y. Bennion, Esq., and Stafford R. Grady, Esq., for the petitioner.

James Powers, Esq., for the respondent.

The respondent determined a deficiency in the income tax of petitioner for the year 1947 in the amount of $50,525.94. The sole issue is whether the gain realized by petitioner upon the sale of the motion picture rights in and to a literary property entitled "Sorry, Wrong Number" constituted long-term capital gain or ordinary income.

FINDINGS OF FACT.

Petitioner is an individual currently residing in Paris, France...

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