United States Tax Court May 21, 1968, Docket Nos. 5013-64, 5014-64 (Martin v. Commissioner)

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.