United States Tax Court March 14, 2013, 13649-10 (Sergio Garcia v. Commissioner)

140 T.C. No. 6

UNITED STATES TAX COURT

SERGIO GARCIA, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 13649-10. Filed March 14, 2013.

P, a professional golfer and a resident of Switzerland, entered

into an endorsement agreement with sponsor T. P agreed to allow T

to use his image, name, and voice (image rights) in advertising and

marketing campaigns worldwide.