William O. Douglas

“ That history strongly suggests that the purpose was not to change the allowable period of allocation from one ending with the close of the taxable year to one covering any 36 months in the past when the work was done, but to prevent tax reduction by proration of income over a period of work greater than the duration of the work preceding the close of the taxable year. ”

“ Section 107 (b) [3] defines 'artistic work' as the 'musical' or 'artistic composition' of an individual, 'the work on which * * * covered a period of thirty-six calendar months or more from the beginning to the completion' of the composition. ”

“ In the legal sense payment of a prize to a winner of a contest is the discharge of a contractual obligation. The acceptance by the contestants of the offer tendered by the sponsor of the contest creates an enforceable contract. ”