Legal Opinion
Peter Stemkowski v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided September 17, 1982No. 1206, Docket 81-4194PublishedCited by 41 opinions
1Opinion of the Court
OAKES, Circuit Judge:
This supposed test case 1 involves the tax-ability of a Canadian citizen who formerly played professional hockey for the New York Rangers of the National Hockey League (NHL). As a nonresident alien, Stemkowski was subject to United States tax on that portion of his income connected with his performance of services in this country, and entitled to deduct expenditures relating to such United States income. The taxable year involved is 1971. After a trial in 1977, the Tax Court, William A. Goffe, Judge, filed an opinion in February 1981, 76 T.C. 252, upholding the…
2Cases cited25 opinions
- Inwood Laboratories, Inc. v. Ives Laboratories, Inc.Supreme Court of the United States · 1982
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Commissioner v. TellierSupreme Court of the United States · 1966
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Commissioner v. ConnellySupreme Court of the United States · 1949
20 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- William J. Kross v. Western Electric Company, Inc.Court of Appeals for the Seventh Circuit · 1983
- Casanova Co. v. CommissionerUnited States Tax Court · 1986
- Robert M. Brown v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1990
- Horton v. CommissionerUnited States Tax Court · 1986
- Charron v. United StatesCourt of Appeals for the Federal Circuit · 1999
36 more not listed; retrieve them via the Exa API.