Passive Activities And Other Oxymorons

Tony Martin, Petitioner, v. Commissioner of Internal Revenue, Respondent. 1. Business bad debt deduction allowed actor for advances designed to a corporation formed to rehabilitate his career. Petitioner is an entertainer and has been so engaged in business since 1932. In 1942 he was the subject of certain unfavorable publicity while offering with the MILITARY. After being discharged from the service in 1945 honorably, petitioner returned to Hollywood to job application his movie profession.

As a consequence of the sooner unfavorable promotion, petitioner was unable to obtain employment in the film industry or in most of the entertainment press. He determined along with certain others to organize a corporation for the intended purpose of producing a one-motion picture starring himself. The business was undertaken mainly to be able to rehabilitate petitioner’s career and to reestablish him in the entertainment field. In order to complete the picture, it was essential for others and petitioner be sure loans to the corporation.

The picture was economically unsuccessful and petitioner’s loan ultimately became worthless.Held, petitioner suffered a reduction from a business bad personal debt deductible completely in the year of losing. J. Everett Blum, Esq., for the petitioner. Joseph G. White, Esq., for the respondent. 4,506.62. Petitioner, by amended petition, claims an overpayment in a total to be determined, if necessary, under a Rule 50 computation. The solitary question shown is whether a loss sustained by petitioner from an unpaid loan is to be deducted as a business bad debts or as a nonbusiness bad personal debt.

The facts are partly stipulated and to the extent so stipulated are integrated herein by guide. Petitioner timely filed a joint Federal income tax comes back for the taxable 12 months 1949 with the collector of internal revenue for the 6th region of California. Because of circumstances undisclosed by the record petitioner in 1942, while the portion with the MILITARY received some unfavorable publicity. 47,250 in accordance with the terms of the contract. It did show up as though petitioner was to get an opportunity to play another role but he was not finally cast in the role and did not play in the picture.

At one point, Goldstone got induced Walter Wanger, a prominent motion picture manufacturer, to consider petitioner for a component in a picture to be produced at Universal International (hereinafter known as U-I). Wanger enthusiastically supported petitioner for the role. However, under Wanger’s partnership arrangement with U-I it had the right of approval of the cast of any pictures produced by it.

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Despite Wanger’s initiatives to secure U-I’s acceptance of petitioner for the role, he had not been so approved and the role went to another. Goldstone obtained the rights to “Pepe le Moko,” personally undertaking the expenditures of options on the house and having a first draft of the screenplay written. He attempted to get rid of this material as a “package then,” including petitioner as the main character. One major studio offered to buy the property from Goldstone for a considerable profit, however they would not do so if necessary to take petitioner as the main character.

Goldstone’s other initiatives to dispose of the house were equally unsuccessful. Encouraged, nevertheless, by the seeming value placed on the property, Goldstone chose that the picture should be produced with petitioner as leading man individually. 900,000. As is customary in this kind of situation, U-I, on whose great deal of the picture was to be produced, was necessary to guarantee the conclusion of the picture.

No other endorsements were required by the lender. 1,200,000, of which the Bank of America was adding some 70-odd per cent. Shortly thereafter it became impossible to secure the discharge of moneys from England, accumulated from the distribution and exhibition of movies there, and it was thought generally that other countries would also soon won’t release such moneys. 41,500, while others loaned varying small amounts. These loans were evidenced by promissory notes executed by Marston to the several lenders, August 1 each dated, 1947, and credited and payable November 15, 1948, bearing interest at 6 % per yr until credited. After completion of the picture it was released for general distribution.