Stemkowski v. Commissioner
United States Tax Court
Petitioners are nonresident alien professional hockey players employed under 12-month contracts. The stated salaries are not apportioned among the following four periods of each year: (1) Training camp, usually the month of September in Canada, (2) regular championship season of play from October through April, (3) the playoff competition following the regular season and ending in May, and (4) the off-season in Canada which lasts until the next training camp.
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Petitioners are nonresident alien professional hockey players employed under 12-month contracts. The stated salaries are not apportioned among the following four periods of each year: (1) Training camp, usually the month of September in Canada, (2) regular championship season of play from October through April, (3) the playoff competition following the regular season and ending in May, and (4) the off-season in Canada which lasts until the next training camp. Held, under sec. 1.861-4(b), Income Tax Regs., the entire stated salaries are paid only for the regular season of play, and only the…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies and increased deficiencies pursuant to section 6214(a), I.R.C. 1954,1 in the Federal income tax of petitioners for the taxable year 1971 as follows:
Income tax deficiency asserted in statutory Increase in deficiency Docket No. notice of deficiency pursuant to sec. 621 Ifa)
4239-75 $5,428.00 $625.00
3485-76 1,663.08 247.32
Upon motion of the parties, these cases were consolidated for purposes of trial, briefs, and opinion. In addition, the parties agree that the instant consolidated case will dispose of all the issues in the following cases…
2Cases cited31 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- United States v. KaiserSupreme Court of the United States · 1960
26 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- Casanova Co. v. CommissionerUnited States Tax Court · 1986
- Robert M. Brown v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1990
- Horton v. CommissionerUnited States Tax Court · 1986
- Favell v. United StatesUnited States Court of Claims · 1989
35 more not listed; retrieve them via the Exa API.