Income Tax Keyed to Freeland
Borge v. Commissioner
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Victor Borge, Petitioner, was a well-known entertainer in the poultry business, and he owned ViBo Farms. He had losses each year that were deducted against income he earned as an entertainer. Petitioner organized a corporation called Danica and transferred ViBo Farms’ assets to Danica. Danica could not meet the losses, and Danica and Petitioner entered into a contract where Petitioner performed entertainment and promotional services for Danica for $50,000 per year. Danica offset the losses against the entertainment profits from Petitioner’s performances. Petitioner was only paid for his services one year. The Commissioner allocated a portion of Danica’s income to Petitioner for the services he performed. The Tax Court upheld the Commissioner and Petitioner appealed.
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