Leavell v. Commissioner
United States Tax Court
P, a professional basketball player, formed a personal service corporation. P agreed to furnish his services to his personal service corporation; the personal service corporation, in turn, executed an NBA Uniform Player Contract with the Rockets to furnish P's services.
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P, a professional basketball player, formed a personal service corporation. P agreed to furnish his services to his personal service corporation; the personal service corporation, in turn, executed an NBA Uniform Player Contract with the Rockets to furnish P's services. As a condition to executing the player contract, the Rockets required P to execute a written agreement with the Rockets wherein P personally agreed to perform the individual services called for by the terms and conditions of the player contract. Held: The Rockets had the right to control the manner and means by which P's…
1Opinion of the Court
Allen Leavell, Petitioner v. Commissioner of Internal Revenue, Respondent
Leavell v. Commissioner
Docket No. 29996-91
United States Tax Court
104 T.C. 140; 1995 U.S. Tax Ct. LEXIS 8; 104 T.C. No. 6;
January 30, 1995, Filed
Decision will be entered under Rule 155.
P, a professional basketball player, formed a personal service corporation. P agreed to furnish his services to his personal service corporation; the personal service corporation, in turn, executed an NBA Uniform Player Contract with the Rockets to furnish P's services. As a condition to executing the player contract, the Rockets required P…
Also in this document: Concurrence · Chiechi; Concurrence · Swift; Dissent.
2Cases cited31 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
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