JOHNSON V. COMMISSIONER
78 T.C. 882 (1982)
NATURE OF THE CASE: This was a dispute over who was actually getting paid for playing
professional basketball.
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.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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