Horner v. Commissioner
United States Tax Court
The petitioner in his individual capacity obtained from the manufacturer of certain merchandise a franchise to sell that merchandise in a stated locality and a line of credit. This merchandise was invoiced to petitioner as an individual but was sold through a corporation of which the petitioner was president, general manager, and major stockholder.
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The petitioner in his individual capacity obtained from the manufacturer of certain merchandise a franchise to sell that merchandise in a stated locality and a line of credit. This merchandise was invoiced to petitioner as an individual but was sold through a corporation of which the petitioner was president, general manager, and major stockholder. He tried to have the invoicing and franchise changed to the corporation but the manufacturer refused to make the change and invoiced all of the merchandise to the petitioner. The invoices were paid by the corporation until it became insolvent. The…
1Opinion of the Court
Harry Horner and Elzora Horner, Petitioners, v. Commissioner of Internal Revenue, Respondent
Horner v. Commissioner
Docket No. 79370
United States Tax Court
35 T.C. 231; 1960 U.S. Tax Ct. LEXIS 30;
November 8, 1960, Filed
Decision will be entered under Rule 50.
The petitioner in his individual capacity obtained from the manufacturer of certain merchandise a franchise to sell that merchandise in a stated locality and a line of credit. This merchandise was invoiced to petitioner as an individual but was sold through a corporation of which the petitioner was president, general manager, and major…
2Cases cited3 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Horner v. CommissionerUnited States Tax Court · 1960
- Sternberg v. CommissionerUnited States Board of Tax Appeals · 1935