Frost v. Commissioner
United States Tax Court
Petitioner received a cash bonus to sign a professional baseball contract and sought to utilize the income-averaging provisions of sec. 1301 et seq. Held: Petitioner cannot utilize such provisions since he is not an "eligible individual" under sec. 1303. Sec. 1303(c)(2)(B) is not applicable since petitioner's training in college during the base period years is not work within the meaning of that provision.
1Opinion of the Court
IRwin, Judge:
Respondent determined a deficiency of $1,825.10 in the income tax of petitioner for the taxable year 1966.
The sole issue for determination is whether petitioner was an “eligible individual” in 1966 within the meaning of section 1303 1 thereby entitling him to the benefit of income averaging under sections 1301 through 1305. The resolution of this issue depends upon whether the $15,000 bonus payment made to petitioner in 1966 by the San Francisco Giants Professional Baseball Club (hereinafter called the Giants) was income attributable to work performed by the petitioner in…
2Cases cited5 opinions
- Robertson v. United StatesSupreme Court of the United States · 1952
- United States v. RobertsonCourt of Appeals for the Tenth Circuit · 1951
- Heidel v. CommissionerUnited States Tax Court · 1971
- Maurice J. Breen and Alyce J. Breen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Wilson v. United StatesDistrict Court, D. Kansas · 1971
3Cited by8 opinions
- Sharvy v. CommissionerUnited States Tax Court · 1977
- Jolitz v. CommissionerUnited States Tax Court · 1980
- Holland v. CommissionerUnited States Tax Court · 1985
- Frost v. CommissionerUnited States Tax Court · 1974
- Hill v. CommissionerUnited States Tax Court · 1979
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