John J. Hanna v. Commissioner of Internal Revenue

In Stemkowski v. Commissioner and in Hanna v. Commissioner, 76 T.C. 252 (1981), two cases which were consolidated by the Tax Court for briefing, trial and rendition of opinion, Judge Goffe disallowed certain allocations and deductions claimed by the two nonresident aliens, both of whom are professional hockey players, in connection with their respective 1971 federal income tax returns. On appeal from Judge Goffe’s opinion, Judge Oakes, writing for the Second Circuit in Stemkowski v. Commissioner, 690 F.2d 40 (2d Cir.1982), aff’d in part and rev’d and remanded in part to the Tax Court.…