Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 54-23

1954-1 C.B. 236

Caution: Obsoleted by Rev. Rul. 69-227

Full Text

Rev. Rul. 54-23

Where a rodeo is conducted by an educational institution which qualifies for exemption from admissions tax, riders competing in the rodeo for prize money under an arrangement with the educational institution whereby the prize money is derived from the entry fees paid by the riders are professional performers within the meaning of section 1701(a)(2)(C) of the Internal Revenue Code, and the prize money paid to the performers is compensation within the meaning of that section. Since the exemption from tax on admissions provided by section 1701 of the Code does not apply to admissions where rodeo performers participate for compensation, the charge for admission to the rodeo, even though conducted by an exempt educational institution, is subject to the tax on admissions. For this purpose, `participating for compensation' means performing for payment whether such payment is received from the admission proceeds or from some other source.