Stemkowski v. Commissioner
United States Tax Court
Petitioners are nonresident alien professional hockey players employed under 12-month contracts. The stated salaries are not apportioned among the following four periods of each year: (1) Training camp, usually the month of September in Canada, (2) regular championship season of play from October through April, (3) the playoff competition following the regular season and ending in May, and (4) the off-season in Canada which lasts until the next training camp.
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Petitioners are nonresident alien professional hockey players employed under 12-month contracts. The stated salaries are not apportioned among the following four periods of each year: (1) Training camp, usually the month of September in Canada, (2) regular championship season of play from October through April, (3) the playoff competition following the regular season and ending in May, and (4) the off-season in Canada which lasts until the next training camp. Held, under sec. 1.861-4(b), Income Tax Regs., the entire stated salaries are paid only for the regular season of play, and only the…
1Opinion of the Court
Peter Stemkowski, Petitioner v. Commissioner of Internal Revenue, Respondent; John J. Hanna, Petitioner v. Commissioner of Internal Revenue, Respondent
Stemkowski v. Commissioner
Docket Nos. 4239-75, 3485-76
United States Tax Court
76 T.C. 252; 1981 U.S. Tax Ct. LEXIS 174;
February 17, 1981, Filed
Decisions will be entered for the respondent in docket Nos. 4239-75 and 3485-76.
Petitioners are nonresident alien professional hockey players employed under 12-month contracts. The stated salaries are not apportioned among the following four periods of each year: (1) Training camp, usually the month of…
2Cases cited32 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- United States v. KaiserSupreme Court of the United States · 1960
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