Leavell v. Commissioner
United States Tax Court
P, a professional basketball player, formed a personal service corporation. P agreed to furnish his services to his personal service corporation; the personal service corporation, in turn, executed an NBA Uniform Player Contract with the Rockets to furnish P's services.
Read the full summary
P, a professional basketball player, formed a personal service corporation. P agreed to furnish his services to his personal service corporation; the personal service corporation, in turn, executed an NBA Uniform Player Contract with the Rockets to furnish P's services. As a condition to executing the player contract, the Rockets required P to execute a written agreement with the Rockets wherein P personally agreed to perform the individual services called for by the terms and conditions of the player contract. Held: The Rockets had the right to control the manner and means by which P's…
1Opinion of the Court
Ruwe, Judge:*
This case is before the Court pursuant to a petition filed by Allen Leavell for redetermination of respondent’s determination of a deficiency of $66,897 in petitioner’s 1985 Federal income tax. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for 1985, the taxable year in issue. Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions by the parties, the sole issue for decision is whether $204,333.35 paid to petitioner’s wholly owned personal service corporation, Allen Leavell, Inc. (corporation), is…
2Cases cited19 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- United States v. SilkSupreme Court of the United States · 1947
- Bartels v. BirminghamSupreme Court of the United States · 1947
14 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Transp. Labor Contract/Leasing, Inc. v. Comm'rUnited States Tax Court · 2004
- Luker v. State Tax AssessorSupreme Judicial Court of Maine · 2011
- TFT Galveston Portfolio, Ltd. Ex Rel. TFT 2, Ltd. v. CommissionerUnited States Tax Court · 2015
- Feaster v. Comm'rUnited States Tax Court · 2010
- Hathaway v. CommissionerUnited States Tax Court · 1996
23 more not listed; retrieve them via the Exa API.