Miller v. Commissioner

Helen Miller (plaintiff), widow of famous musician Glenn Miller, contracted with Universal Pictures to grant exclusive production rights to Glenn's life story, warranting she exclusively owned the rights transferred, and received over $400,000 as her share of proceeds from the resulting film. Helen reported this payment as capital gain from the sale of a capital asset on her taxes, but the Commissioner (defendant) determined it was ordinary income; the Tax Court sustained the Commissioner's position, and Helen petitioned for review.