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Johnson v. Commissioner
United States Tax Court (1982) | 1982 U.S. Tax Ct. LEXIS 91; 78 T.C. No. 62; 78 T.C. 882
TL;DR: A professional basketball player contracted his services to his personal corporation, but his NBA team refused to contract with the entity. The court held the player, not the corporation, was the true earner of the income because the team contracted directly with him.
Legal Significance: This case establishes a key two-part test for determining whether a personal service corporation or its employee is the true earner of income, emphasizing the necessity of a contract between the corporation and the service-recipient.