Legal Opinion

Kramer v. Comm'r

United States Tax Court

Decided April 25, 1983No. Docket No. 3911-79Published

T, a former amateur and professional tennis champion, was paid substantial royalties by W in 1975 and 1976 from the sale of tennis equipment, primarily racquets, bearing his name.

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T, a former amateur and professional tennis champion, was paid substantial royalties by W in 1975 and 1976 from the sale of tennis equipment, primarily racquets, bearing his name. The contract pursuant to which the royalties were paid required not only that T grant W exclusive rights to manufacture and sell tennis equipment under his name, but also that he make promotional appearances and participate in other promotional activities on behalf of W. Although T rendered personal services thus required of him, he was also extensively engaged in activities in the tennis world wholly apart from…

1Opinion of the Court

John A. Kramer and Gloria L. Kramer, Petitioners v. Commissioner of Internal Revenue, Respondent

Kramer v. Comm'r

Docket No. 3911-79

United States Tax Court

80 T.C. 768; 1983 U.S. Tax Ct. LEXIS 93; 80 T.C. No. 38; 221 U.S.P.Q. (BNA) 268;

April 25, 1983, Filed

Decision will be entered under Rule 155.

T, a former amateur and professional tennis champion, was paid substantial royalties by W in 1975 and 1976 from the sale of tennis equipment, primarily racquets, bearing his name. The contract pursuant to which the royalties were paid required not only that T grant W exclusive rights to manufacture and…

2Cases cited12 opinions

  1. Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
  2. Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
  3. Etta Potson Bodoglau, Administratrix of the Estate of Michael Potson, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
  4. Walter E. Ditmars and Jennie J. Ditmars v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
  5. Seattle Brewing & Malting Co. v. Comm'rUnited States Tax Court · 1946

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