Johnson v. Commissioner
United States Tax Court
Petitioner, a professional basketball player, executed a contract with an unrelated corporation whereby he granted the corporation the right to his services in professional sports for a limited time, and the corporation agreed to pay petitioner a monthly sum. Petitioner played for a professional basketball club with which he signed player contracts.
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Petitioner, a professional basketball player, executed a contract with an unrelated corporation whereby he granted the corporation the right to his services in professional sports for a limited time, and the corporation agreed to pay petitioner a monthly sum. Petitioner played for a professional basketball club with which he signed player contracts. The club remitted the compensation for petitioner's services to the corporation pursuant to assignments of contract rights executed by petitioner. However, there existed no contract between the club and the corporation. Held, petitioner, rather…
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies of $34,698, $35,747, and $40,832 in petitioner’s Federal income tax for 1975, 1976, and 1977, respectively. At issue is whether amounts paid by a professional basketball club with respect to petitioner’s services are income to petitioner or to a corporation to which the payments were made.
These cases are consolidated for trial, briefing, and opinion.
FINDINGS OF FACT
Some facts are stipulated and found accordingly.
Petitioner Charles Johnson was a resident of Oakland, Calif., when he filed his petitions herein.
During the years in issue, Charles…
2Cases cited23 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Higgins v. SmithSupreme Court of the United States · 1940
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- United States v. BasyeSupreme Court of the United States · 1973
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3Cited by66 opinions
- Haag v. CommissionerUnited States Tax Court · 1987
- Charles Johnson v. United StatesCourt of Appeals for the Ninth Circuit · 1983
- Kanter v. CommissionerCourt of Appeals for the Seventh Circuit · 2009
- Bagley v. CommissionerUnited States Tax Court · 1985
- Leavell v. CommissionerUnited States Tax Court · 1995
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