Hyatt v. Commissioner
United States Board of Tax Appeals
The taxpayer, licensed by the manufacturer to sell and apply a preparation against termites and guaranteeing effectiveness for five years, was required by the license contract to send to the licensor 10 percent of the price of his contracts with customers, to be held in escrow as a guaranty fund until expiration of the guaranty period; this requirement he fulfilled only in part. The full amount of the contract prices should be included in the taxpayer's income.
1Opinion of the Court
GEORGE HYATT, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hyatt v. Commissioner
Docket No. 82594.
United States Board of Tax Appeals
36 B.T.A. 121; 1937 BTA LEXIS 773;
June 15, 1937, Promulgated
The taxpayer, licensed by the manufacturer to sell and apply a preparation against termites and guaranteeing effectiveness for five years, was required by the license contract to send to the licensor 10 percent of the price of his contracts with customers, to be held in escrow as a guaranty fund until expiration of the guaranty period; this requirement he fulfilled only in part. The full…
2Cases cited5 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Bassett v. CommissionerUnited States Board of Tax Appeals · 1935
- Gibbs & Hudson v. CommissionerUnited States Board of Tax Appeals · 1936
- Consolidated Asphalt Co. v. CommissionerUnited States Board of Tax Appeals · 1924
- Hyatt v. CommissionerUnited States Board of Tax Appeals · 1937