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.
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