Handfield v. Commissioner
United States Tax Court
Petitioner, a Canadian, manufactured postal cards in Canada which were sold in the United States through an agreement with a news company. Held, under the agreement, the news company was the petitioner's agent for distributing the cards in the United States. Thus, petitioner was engaged in business within the United States and income from sales in this country is subject to income taxes.
1Opinion of the Court
Frank Handfield, Petitioner, v. Commissioner of Internal Revenue, Respondent
Handfield v. Commissioner
Docket No. 40251
United States Tax Court
23 T.C. 633; 1955 U.S. Tax Ct. LEXIS 270;
January 17, 1955, Filed
Decision will be entered under Rule 50.
Petitioner, a Canadian, manufactured postal cards in Canada which were sold in the United States through an agreement with a news company. Held, under the agreement, the news company was the petitioner's agent for distributing the cards in the United States. Thus, petitioner was engaged in business within the United States and income from sales in this…
2Cases cited6 opinions
- Ludvigh v. American Woolen Co. of NYSupreme Court of the United States · 1913
- McCallum v. Bray-Robinson Clothing Co.Court of Appeals for the Sixth Circuit · 1928
- Edgewood Shoe Factories, Division of General Shoe Corp. v. StewartCourt of Appeals for the Fifth Circuit · 1939
- Handfield v. CommissionerUnited States Tax Court · 1955
- In Re TaylorDistrict Court, E.D. Michigan · 1931
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