actual value of the subject master equaled between $3,000 and $5,000. Included in Encore’s prospectus package is a list of distributors with respect to the distribution of sound recordings made from the subject master recording. Petitioner entered into a standard distribution-employment agreement with Arrival Records and did not modify any of the terms of the agreement before signing. Petitioner’s distribution agreement with Arrival was subsequently assigned to Marock Records. During the term of the lease between petitioner and Encore, total income derived from sales of albums and cassettes made from the Kingcannon master totaled $570.85. Petitioner’s share of the income from sales of albums and cassettes made from the subject master totaled $18.57. The primary purchaser of the sound recordings made from the master was the artists, the Kingcannon family. During the term of the lease, petitioner did not personally distribute sound recordings made from the subject master. During 1984, petitioner worked as an agent for Encore selling its tax shelters at a commission rate of 20 percent of receipts from the sales of leases. During the latter part of 1984, petitioner issued three newsletters directed to his master recording lease clients. Each newsletter was entitled DERWYN J. BOOKER, TAX ADVANTAGED INVESTMENT COUNSELING.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011