# Martin v. Commissioner

> United States Tax Court · May 21, 1968 · 50 T.C. 341

URL: https://www.frixlaw.com/law-library/cases/4480987

## Case

- **Full name:** Ernest H. Martin and Nancy G. Martin v. Commissioner of Internal Revenue, Respondent Cy Feuer and Posy Lee Feuer v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** May 21, 1968
- **Citations:** 50 T.C. 341; 1968 U.S. Tax Ct. LEXIS 123
- **Precedential status:** Published
- **Opinion:** Dissent by Kaum
- **Judges:** Atkins,Raum,Drennen,Tannenwald,Fay,Tannenwald,Drennen,Tietjens,Raum,Simpson
- **Cited by:** 12 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4480987

## Opinion text

Kaum, J., dissenting: I join in Judge Tannenwald’s dissenting opinion, but wish merely to add a word about Fred MacMurray, 21 T.C. 15 , and Anatole L. Litvak, 23 T.C. 441 . Here, petitioners, as a regular and recurring part of their operations, derived income from the sale of motion-picture rights in respect of stories forming the basis for tbe conduct of their business as producers. I think it should be of no consequence what form such sales took; nor should it be a matter of critical importance that the sales had their origin in circumstances like those presented in this case. MacMurray and Litvak involved only isolated sales, and are therefore sharply to be distinguished.
DreNNEN and TáNNENWAld, //., agree with this dissenting opinion.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4480987. Public record. Not legal advice.