Robinson v. Commissioner
United States Tax Court
1. Held, T, a professional boxer who filed 1957 income tax return on cash basis, was not chargeable with any greater amount of income in 1957 from a certain championship match than was actually received by him or paid out for his benefit from his contractual share of the receipts. He was not a member of a joint venture in respect of that match; nor was the contract providing for deferred payments a sham.
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1. Held, T, a professional boxer who filed 1957 income tax return on cash basis, was not chargeable with any greater amount of income in 1957 from a certain championship match than was actually received by him or paid out for his benefit from his contractual share of the receipts. He was not a member of a joint venture in respect of that match; nor was the contract providing for deferred payments a sham. There was no constructive receipt of any amount in excess of that reported. 2. Held, a cash payment of $ 10,000 to or in behalf of T to open his training camp represented unreported income.…
1Opinion of the Court
OPINION
Raum, Judge:
1. Tarnation of Robinson's Share of Proceeds of Fight.- — Petitioner’s share of the proceeds of his fight with Basilio on September 23,1957, was $483,666.71, exclusive of motion-picture rights, and, by the end of 1957, his share in the proceeds of the sale of the motion-picture rights amounted to $32,516.74. As a result of the events described in our findings, he received or there was paid out in his behalf during 1957 in respect of that fight a total of $139,600, which he reported in his 1957 return. The Commissioner’s original determination of deficiency for 1957 charged…
2Cases cited18 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Ruben v. CommissionerUnited States Tax Court · 1960
- Steinbeck v. GerosaNew York Court of Appeals · 1958
- Luna v. CommissionerUnited States Tax Court · 1964
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
13 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- n.sidney Nyhus v. Travel Management CorporationCourt of Appeals for the D.C. Circuit · 1972
- Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- Griffith v. CommissionerUnited States Tax Court · 1980
- Goldsmith v. United StatesUnited States Court of Claims · 1978
- Arnwine v. CommissionerUnited States Tax Court · 1981
6 more not listed; retrieve them via the Exa API.