Frost v. Commissioner
United States Tax Court
Petitioner received a cash bonus to sign a professional baseball contract and sought to utilize the income-averaging provisions of sec. 1301 et seq. Held: Petitioner cannot utilize such provisions since he is not an "eligible individual" under sec. 1303. Sec. 1303(c)(2)(B) is not applicable since petitioner's training in college during the base period years is not work within the meaning of that provision.
1Opinion of the Court
William L. Frost, Petitioner v. Commissioner of Internal Revenue, Respondent
Frost v. Commissioner
Docket No. 2146-71
United States Tax Court
61 T.C. 488; 1974 U.S. Tax Ct. LEXIS 164;
January 28, 1974, Filed
Decision will be entered for the respondent.
Petitioner received a cash bonus to sign a professional baseball contract and sought to utilize the income-averaging provisions of sec. 1301 et seq. Held: Petitioner cannot utilize such provisions since he is not an "eligible individual" under sec. 1303. Sec. 1303(c)(2)(B) is not applicable since petitioner's training in college during the base period…
2Cases cited6 opinions
- Robertson v. United StatesSupreme Court of the United States · 1952
- United States v. RobertsonCourt of Appeals for the Tenth Circuit · 1951
- Heidel v. CommissionerUnited States Tax Court · 1971
- Maurice J. Breen and Alyce J. Breen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Frost v. CommissionerUnited States Tax Court · 1974
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