Hornaday v. Commissioner
United States Tax Court
In 1977, 1978, and 1979, P received $ 40,000 under a contract (the "consulting contract") entered into between Guilford Mills, Inc., and P pursuant to the terms of which P promised to perform consulting services to Guilford Mills, Inc., whenever that company requested.
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In 1977, 1978, and 1979, P received $ 40,000 under a contract (the "consulting contract") entered into between Guilford Mills, Inc., and P pursuant to the terms of which P promised to perform consulting services to Guilford Mills, Inc., whenever that company requested. P did not at any time offer consulting services to any individual or entity other than Guilford Mills, Inc. Held, under all of the facts and circumstances of this case, P was engaged in the trade or business of consulting during the years in issue and the fact that P offered consulting services to only Guilford Mills, Inc., is…
1Opinion of the Court
Kórner, Judge:
Respondent determined deficiencies in petitioners’ Federal self-employment taxes as follows:’
Year Deficiency
1977 . $1,304
1978 . 1,434
1979 . 1,855
The sole issue for decision is whether money received by petitioner James M. Hornaday under a contract between him and Guilford Mills, Inc., is self-employment income subject to tax under section 1401.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulations of fact, together with the exhibits attached thereto, are incorporated herein by this reference.
James M. (hereinafter petitioner) and Virginia A.…
2Cases cited16 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Yelencsics v. CommissionerUnited States Tax Court · 1980
- George F. Delno v. Anthony J. Celebrezze, Secretary of Health, Education and WelfareCourt of Appeals for the Ninth Circuit · 1965
- Gentile v. CommissionerUnited States Tax Court · 1975
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