ARLEN v. COMMISSIONER

Docket No. 2109-65.

48 T.C. 640 (1967)

HAROLD ARLEN AND ANYA ARLEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 3, 1967.


Attorney(s) appearing for the Case

Benjamin Alpert and Myles J. Sachs, for the petitioners.

William F. Chapman, for the respondent.


ARUNDELL, Judge:

Respondent determined a deficiency in income tax for the calendar year 1959 in the amount of $41,413.

The only remaining issue is whether an amount of $50,000 received in 1959 by petitioner Harold Arlen, a composer of popular music, from Music Publishers Holding Corp. was received as a bona fide loan or was received as advance royalties.

Other errors were assigned but have been agreed upon. Effect will be given to these agreements...

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