Linseman v. Commissioner
United States Tax Court
Petitioner, a nonresident alien, received a sign-on bonus to enter into an agreement to play professional hockey for B, a U.S. taxpayer. Held, the sign-on bonus is to be allocated to sources within and without the United States, under sec. 863, I.R.C. 1954, on the basis of the number of games played by B during the season within and without the United States.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency of $5,079 in petitioner’s Federal income tax for the taxable year 1977 and an addition to tax of $762 under section 6651(a)(1)1 for late filing of petitioner’s return for that year. The issues for decision are (1) how a sign-on bonus paid by a domestic professional sports club to a nonresident alien should be allocated to sources within and without the United States, (2) whether certain business expenses are deductible, and (3) whether petitioner had reasonable cause for failure to file a timely return.
FINDINGS OF FACT
Some of the facts have…
2Cases cited7 opinions
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Peter Stemkowski v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1982
- United States v. KaufmanSupreme Court of the United States · 1925
- Stemkowski v. CommissionerUnited States Tax Court · 1981
- Linseman v. World Hockey Ass'nDistrict Court, D. Connecticut · 1977
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Knowlton v. CommissionerUnited States Tax Court · 1985
- Nunn v. Comm'rUnited States Tax Court · 2002
- Berg v. CommissionerUnited States Tax Court · 1989
- HESS v. COMMISSIONERUnited States Tax Court · 2002
- Knowlton v. CommissionerUnited States Tax Court · 1985
1 more not listed; retrieve them via the Exa API.