Legal Opinion

Robinson v. Commissioner

United States Tax Court

Decided April 6, 1965No. Docket No. 89128PublishedCited by 11 opinions

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.

Read the full summary

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

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Ruben v. CommissionerUnited States Tax Court · 1960
  3. Steinbeck v. GerosaNew York Court of Appeals · 1958
  4. Luna v. CommissionerUnited States Tax Court · 1964
  5. Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957

13 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. n.sidney Nyhus v. Travel Management CorporationCourt of Appeals for the D.C. Circuit · 1972
  2. Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
  3. Griffith v. CommissionerUnited States Tax Court · 1980
  4. Goldsmith v. United StatesUnited States Court of Claims · 1978
  5. Arnwine v. CommissionerUnited States Tax Court · 1981

6 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API