Legal Opinion
Sergio Garcia v. Commissioner
United States Tax Court
Decided March 14, 2013No. 13649-10Published
1Opinion of the Court
140 T.C. No. 6
UNITED STATES TAX COURT SERGIO GARCIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13649-10. Filed March 14, 2013. P, a professional golfer and a resident of Switzerland, entered into an endorsement agreement with sponsor T. P agreed to allow T to use his image, name, and voice (image rights) in advertising and marketing campaigns worldwide. P also agreed to perform personal services for T including using T’s products in all his golf play, posing and acting for advertisements, and making personal appearances for the company. In return for his services…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Joseph R. Dileo, Mary A. Dileo, Walter E. Mycek, Jr., Michele A. Mycek and Arcelo Reproduction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992
- Kolovrat v. OregonSupreme Court of the United States · 1961
- Haelan Laboratories, Inc. v. Topps Chewing Gum, Inc.Court of Appeals for the Second Circuit · 1953
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