Legal Opinion

Robinson v. Commissioner

United States Tax Court

Decided April 6, 1965No. Docket No. 89128Published

1. Held, T, a professional boxer who filed 1957 income tax return on cash basis, was not chargeable with any greater amount of income in 1957 from a certain championship match than was actually received by him or paid out for his benefit from his contractual share of the receipts. He was not a member of a joint venture in respect of that match; nor was the contract providing for deferred payments a sham.

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1. Held, T, a professional boxer who filed 1957 income tax return on cash basis, was not chargeable with any greater amount of income in 1957 from a certain championship match than was actually received by him or paid out for his benefit from his contractual share of the receipts. He was not a member of a joint venture in respect of that match; nor was the contract providing for deferred payments a sham. There was no constructive receipt of any amount in excess of that reported. 2. Held, a cash payment of $ 10,000 to or in behalf of T to open his training camp represented unreported income.…

1Opinion of the Court

Ray S. Robinson and Edna Mae Robinson, Petitioners, v. Commissioner of Internal Revenue, Respondent

Robinson v. Commissioner

Docket No. 89128

United States Tax Court

44 T.C. 20; 1965 U.S. Tax Ct. LEXIS 104;

April 6, 1965, Filed

Decision will be entered under Rule 50.

1. Held, T, a professional boxer who filed 1957 income tax return on cash basis, was not chargeable with any greater amount of income in 1957 from a certain championship match than was actually received by him or paid out for his benefit from his contractual share of the receipts. He was not a member of a joint venture in respect of…

2Cases cited19 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Ruben v. CommissionerUnited States Tax Court · 1960
  3. Steinbeck v. GerosaNew York Court of Appeals · 1958
  4. Luna v. CommissionerUnited States Tax Court · 1964
  5. Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957

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