Saturday, March 16, 2013
In Garcia v. Commissioner, 140 T.C. No. 6 (Mar. 14, 2013), the Tax Court allocated 65% of golfer Sergio Garcia's compensation from his contract with golf club manufacturer TaylorMade to royalties (for use of his image rights) (and thus not subject to U.S. taxation) and 35% to personal services (and thus subject to U.S. taxation), rather than the 85%/15% split provided for in the contract.