Johnson v. Commissioner

78 T.C. 882 (1982)

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Nature of the Case

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Facts

P was a professional basketball player. P executed a contract with PMSA granting it the right to his services in professional sports for a limited time. PMSA was obligated to pay P's monthly salary. PMSA then licensed its rights to EST who made the payments to P and remitted 95% of its net revenue to PMSA. P signed a professional basketball contract with the Warriors and assigned all his rights to EST. The Warriors made their compensation payments to EST. P contends that the amounts paid directly to EST for his services as a basketball player were taxable income to EST only and he was not liable for any taxes.