Robert M. Brown v. Commissioner of Internal Revenue

Taxpayer/petitioner Robert M. Brown is one of approximately 230 professional hockey players who, in 1975, received deficiency notices from the IRS for deductions for off-season expenses claimed in their 1972 income tax returns. In an effort to resolve these cases expeditiously, the Tax Court directed counsel and the Commissioner to designate two representative cases for litigation. 1 The outcome of the test cases would, in theory, guide the disposition, either through settlement or litigation, of both the hockey and non-hockey issues raised in the remaining cases. What was intended as…