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LINSEMAN v. COMMISSIONER

Docket No. 23315-81.

082 T.C. 514 (1984)

KEN LINSEMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1984.

Attorney(s) appearing for the Case

Howard J. Schwartz, for the petitioner.

Donald Rightnour, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $5,079 in petitioner's Federal income tax for the taxable year 1977 and an addition to tax of $762 under section 6651(a)(1)1 for late filing of petitioner's return for that year. The issues for decision are (1) how a sign-on bonus paid by a domestic professional sports club to a nonresident alien should be allocated to sources within and without the United States, (2) whether...

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