Hollywood Baseball Asso. v. Commissioner
United States Tax Court
It was necessary for petitioner, a minor league baseball club, to enter into working agreements and a league agreement in order to obtain player contracts and participate in organized baseball. Such agreements required sales of such contracts on demand.
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It was necessary for petitioner, a minor league baseball club, to enter into working agreements and a league agreement in order to obtain player contracts and participate in organized baseball. Such agreements required sales of such contracts on demand. Held: This entire arrangement was an integral part of, and at the heart and core of petitioner's business; therefore, the player contracts were a part of petitioner's stock in trade and petitioner's primary and principal purpose in holding such contracts was to sell them in the ordinary course of its business. Profits from such sales are to be…
1Opinion of the Court
OPINION
The issue for consideration is whether petitioner’s sales of certain player contracts produced income which is not to be recognized by it under section 337 of the Code.2
Respondent contends that the profits from the sales of the players’ contracts are excluded from nonrecognition under section 837 (b) (1) (A), and that two of the contracts were in fact sold prior to the adoption of the plan of liquidation. As in our previous opinion in this case, we again find it unnecessary to pass upon respondent’s later contention, because we find and hold that such contracts did fall within the…
2Cases cited24 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
- Hort v. CommissionerSupreme Court of the United States · 1941
19 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Hollywood Baseball Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Gamble v. CommissionerUnited States Tax Court · 1977
- Buena Vista Farms, Inc. v. CommissionerUnited States Tax Court · 1977
- Estate of Shea v. CommissionerUnited States Tax Court · 1971
- Buena Vista Farms, Inc. v. CommissionerUnited States Tax Court · 1977
8 more not listed; retrieve them via the Exa API.