Hundley v. Commissioner
United States Tax Court
Petitioner entered into an agreement with his father in 1958 to share equally any bonus he might receive for signing a professional baseball contract as compensation for his father's coaching efforts to make him a better baseball player, to serve as his business manager, advisor, and agent and to obtain the best possible professional baseball contract for him.
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Petitioner entered into an agreement with his father in 1958 to share equally any bonus he might receive for signing a professional baseball contract as compensation for his father's coaching efforts to make him a better baseball player, to serve as his business manager, advisor, and agent and to obtain the best possible professional baseball contract for him. Petitioner signed a professional baseball contract in 1960 as a result of his father's exceptional representation and negotiating skill which provided for a monthly salary of not less than $ 1,000 for the length of his contract and a…
1Opinion of the Court
Hoyt, Judge:
Respondent determined a deficiency in petitioner’s income tax for 1960 in the amount of $5,334.85. The only question presented for our decision is what portion of a $22,000 cash bonus earned by petitioner in 1960 for signing a professional baseball contract is deductible as the reasonable value of services actually performed by petitioner’s father.
FINDINGS OF FACT
The stipulated facts are found accordingly and adopted as our findings.
Cecil Randolph Hundley, Jr. (hereinafter referred to as petitioner), filed his 1960 income tax return with the district director of internal revenue,…
2Cases cited13 opinions
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Frank v. CommissionerUnited States Tax Court · 1953
- Polachek v. CommissionerUnited States Tax Court · 1954
- Walet v. CommissionerUnited States Tax Court · 1958
- Eugene H. Walet, Jr. And Celia R. Walet v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
8 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Jackson v. CommissionerUnited States Tax Court · 1972
- American Foundry v. CommissionerUnited States Tax Court · 1972
- Rotolo v. CommissionerUnited States Tax Court · 1987
- Allen v. CommissionerUnited States Tax Court · 1968
- Fritschle v. CommissionerUnited States Tax Court · 1982
6 more not listed; retrieve them via the Exa API.