Legal Opinion

Goosen v. Commissioner

United States Tax Court

Decided June 9, 2011No. Docket No. 23323-09PublishedCited by 5 opinions

P, a professional golfer, entered into endorsement agreements with sponsors Acushnet, TaylorMade, Izod, Upper Deck, Electronic Arts and Rolex. P agreed to allow all sponsors to use his name, face, image and likeness in advertising and marketing campaigns worldwide. P also agreed to perform some services for the sponsors. All endorsement agreements paid P a base endorsement fee.

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P, a professional golfer, entered into endorsement agreements with sponsors Acushnet, TaylorMade, Izod, Upper Deck, Electronic Arts and Rolex. P agreed to allow all sponsors to use his name, face, image and likeness in advertising and marketing campaigns worldwide. P also agreed to perform some services for the sponsors. All endorsement agreements paid P a base endorsement fee. Acushnet, TaylorMade and Izod prorated P's base endorsement fee if he did not annually play in a specified number of golf tournaments. Moreover, Acushnet, TaylorMade and Izod provided bonuses to P for achieving a…

1Opinion of the Court

Kroupa, Judge:

Respondent determined that petitioner, a non-domiciliary United Kingdom (U.K.) resident, had Federal income tax deficiencies from income he received from worldwide endorsement agreements for 2002 and 2003 (the years at issue). Respondent determined a $20,224 deficiency for 2002 and a $144,474 deficiency for 2003.

After concessions, there are three issues for decision. The first issue is whether endorsement fees and bonuses petitioner, a U.K. resident, received from worldwide endorsement agreements with Acushnet Company (Acushnet), TaylorMade Golf Company, Inc. (TaylorMade) and…

2Cases cited17 opinions

  1. Haelan Laboratories, Inc. v. Topps Chewing Gum, Inc.Court of Appeals for the Second Circuit · 1953
  2. Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
  3. Rohmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
  4. United States v. Everett W. Gross and L. Mary GrossCourt of Appeals for the Eighth Circuit · 1969
  5. Ferrer v. CommissionerUnited States Tax Court · 1961

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

3Cited by5 opinions

  1. Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
  2. Cohan v. Comm'rUnited States Tax Court · 2012
  3. Garcia v. CommissionerUnited States Tax Court · 2013
  4. K. Slaughter v. CommissionerUnited States Tax Court · 2019
  5. Sergio Garcia v. CommissionerUnited States Tax Court · 2013

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