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