Allen v. Commissioner
United States Tax Court
Held, that portion of a bonus for the signing of a contract by petitioner (a minor) to play baseball for a professional baseball team which was paid directly to his mother by prearrangement in the contract was taxable to petitioner under sec. 73 or sec. 61, I.R.C. 1954. Held, further, petitioner was not entitled to deduct from his gross income any part of the bonus payments made to his mother during the years here in issue.
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Held, that portion of a bonus for the signing of a contract by petitioner (a minor) to play baseball for a professional baseball team which was paid directly to his mother by prearrangement in the contract was taxable to petitioner under sec. 73 or sec. 61, I.R.C. 1954. Held, further, petitioner was not entitled to deduct from his gross income any part of the bonus payments made to his mother during the years here in issue. Cecil Randolph Hundley, Jr., 48 T.C. 339, distinguished.
1Opinion of the Court
Richard A. Allen and Barbara Allen, Petitioners v. Commissioner of Internal Revenue, Respondent; Richard A. Allen, Petitioner v. Commissioner of Internal Revenue, Respondent
Allen v. Commissioner
Docket Nos. 2503-66, 2504-66
United States Tax Court
50 T.C. 466; 1968 U.S. Tax Ct. LEXIS 107;
June 24, 1968, Filed
Decisions will be entered for the respondent.
Held, that portion of a bonus for the signing of a contract by petitioner (a minor) to play baseball for a professional baseball team which was paid directly to his mother by prearrangement in the contract was taxable to petitioner under sec. 73 or…
2Cases cited9 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Helvering v. EubankSupreme Court of the United States · 1941
- De Korse v. CommissionerUnited States Tax Court · 1945
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