Hollywood Baseball Ass'n v. Commissioner
United States Tax Court
The Brooklyn Dodgers and New York Giants of the major National League transferred their baseball organizations to the Los Angeles and San Francisco areas prior to the commencement of the 1958 professional baseball season. These areas had formerly been controlled by the minor Pacific Coast League.
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The Brooklyn Dodgers and New York Giants of the major National League transferred their baseball organizations to the Los Angeles and San Francisco areas prior to the commencement of the 1958 professional baseball season. These areas had formerly been controlled by the minor Pacific Coast League. As a result of the transfer, the Pacific Coast League Hollywood Stars baseball organization adopted a plan of liquidation pursuant to section 337, I.R.C. 1954. Held: 1. Payments for the nonbulk sale of certain baseball player contracts are not within the purview of section 337; 2. Consideration for…
1Opinion of the Court
FORRESTER, Judge:
Respondent has determined deficiencies of $25,502.01, $20,004.38, and $8,760.08 for the taxable years ending October 31,1955, October 31,1956, and October 31,1958,1 respectively. The three remaining issues before us are as follows:
Whether gain realized from the sale of certain baseball player contracts is within the purview of section 337;
Whether an amount realized pursuant to the transfer of two major league baseball teams to the Pacific coast area is taxable as ordinary income to petitioner; and
Whether the petitioner is entitled to a claimed deduction for organizational…
Also in this document: Concurrence.
2Cases cited92 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Radovich v. National Football LeagueSupreme Court of the United States · 1957
87 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Duncan Industries, Inc., etc. v. CommissionerUnited States Tax Court · 1979
- Verito v. CommissionerUnited States Tax Court · 1965
- Anders v. CommissionerUnited States Tax Court · 1967
- Westchester Dev. Co. v. CommissionerUnited States Tax Court · 1974
- Potter v. CommissionerUnited States Tax Court · 1965
21 more not listed; retrieve them via the Exa API.