Johnson v. Commissioner
United States Tax Court
78 T.C. 882 (1982)
Johnson (plaintiff) was a professional basketball player who signed a contract with Presentaciones Musicales (PMSA). PMSA acquired the right to Johnson’s services in professional basketball and in return paid Johnson a monthly salary. PMSA assigned its rights to EST International Ltd. (EST), who thereafter paid salary to Johnson and retained five percent of the net revenue while remitting the remainder to PMSA. Johnson separately signed a contract with the Warriors. He assigned all his rights in the contract to EST. The Warriors paid Johnson’s salary directly to EST.
Rule of Law
Holding and Reasoning (Fay, J.)
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