Kramer v. Comm'r
United States Tax Court
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
Raum, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income taxes for 1975 and 1976 in the amounts of $15,752 and $23,088, respectively. The sole issue for decision is whether certain amounts received by petitioner John A. Kramer during those years constituted "earned income” for purposes of the maximum tax on earned income and the computation of the maximum deductible contribution to a self-employment pension (Keogh) plan.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Peti…
2Cases cited11 opinions
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Commissioner of Internal Revenue v. José FerrerCourt of Appeals for the Second Circuit · 1962
- Etta Potson Bodoglau, Administratrix of the Estate of Michael Potson, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Walter E. Ditmars and Jennie J. Ditmars v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- Seattle Brewing & Malting Co. v. Comm'rUnited States Tax Court · 1946
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Thomas v. CommissionerUnited States Tax Court · 1989
- Goosen v. CommissionerUnited States Tax Court · 2011
- Garcia v. CommissionerUnited States Tax Court · 2013
- K. Slaughter v. CommissionerUnited States Tax Court · 2019
- Kramer v. Comm'rUnited States Tax Court · 1983
3 more not listed; retrieve them via the Exa API.