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Goosen v. Commissioner

136 T.C. 547 (2011)

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Goosen v. Commissioner

United States Tax Court
136 T.C. 547 (2011)

SH

Facts

Retief Goosen (plaintiff) was a British citizen and professional golfer who entered into endorsement agreements with Acushnet, TaylorMade, and Izod (sponsors), among others. Goosen agreed to allow the sponsors to use his name and likeness for advertising and promotional materials worldwide and to wear or use their products during tournaments. The sponsors agreed to compensate Goosen with a base endorsement fee, but that fee was prorated if Goosen did not compete in a specified number of tournaments. The sponsors also agreed to offer bonuses to Goosen if he achieved a specific finish in a Professional Gold Association (PGA) or European Tour tournament. Goosen characterized the endorsements fees and bonuses earned from the sponsors as 50 percent personal-services income and 50 percent royalty income on his nonresident federal income tax returns for 2002 and 2003. The Internal Revenue Service (IRS) determined that Goosen should have characterized the endorsement fees and bonuses from the sponsors as 100 percent personal-services income. Goosen filed a petition challenging the IRS’s determination.

Rule of Law

Issue

Holding and Reasoning (Kroupa, J.)

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