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Sargent v. Commissioner

United States Court of Appeals for the Eighth Circuit
929 F.2d 1252 (1991)


Sargent and Christoff (plaintiffs) were professional hockey players for the Minnesota North Stars. Sargent and Christoff hired personal service corporations to represent their business interests as hockey players. The North Stars contracted with the players’ personal service corporations for the right to have the players play on the team. The personal service corporations in turn paid Sargent and Christoff a salary and also contributed to the personal service corporations’ qualified pension plans. The Internal Revenue Service (IRS) (defendant) disallowed deductions for the players’ pension contributions and proposed to tax the players on the entire amount that the North Stars paid the personal service corporations. The United States Tax Court affirmed the IRS’s decision. Sargent and Christoff appealed.

Rule of Law


Holding and Reasoning (Bogue, J.)

Dissent (Arnold, J.)

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