Commissioner of Internal Revenue v. Pittsburgh Athletic Co.

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The respondent, a baseball club belonging to the National League, purchased players’ contracts at varying prices. Each contract provided for the employment of die named baseball player at a stipulated salary for all games played by the respondent during the designated year, and also provided that the contract could be assigned or terminated by the respondent or its assignee during that year upon ten days’ written notice to the player.

Paragraph 8 of each contract reads:

“(a) On or before February…