Mackinac Island Carriage Tours, Inc. v. Commissioner

JOHN W. PECK, Circuit Judge.

These are combined appeals by the taxpayer and cross-appeal by the government from the judgment of the Tax Court.

The taxpayer is a Michigan corporation which operates horse drawn carriage tours on Mackinac Island. Such carriages, except for bicycles, constitute virtually the only means of transportation on the island. For many years the State of Michigan and the City of Mackinac granted yearly licenses to individuals to operate the carriage tours. In 1948, following complaints about bad service, the State required the individual operators to form a corporation with…