Legal Opinion

Horne v. Commissioner

United States Tax Court

Decided November 27, 1972No. Docket No. 2645-70Published

Petitioner (husband) was a partner in a three-man firm. The three partners, as individuals, owned all the stock in COINC, which, in turn, owned all the stock in CORP and CO. All three corporations performed construction work. N/A, a bonding company, wrote bonds for all three corporations. All three corporations indemnified N/A on cross-indemnity agreements. In 1960, CO notified N/A that it, N/A, would have to perform on its bond.

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Petitioner (husband) was a partner in a three-man firm. The three partners, as individuals, owned all the stock in COINC, which, in turn, owned all the stock in CORP and CO. All three corporations performed construction work. N/A, a bonding company, wrote bonds for all three corporations. All three corporations indemnified N/A on cross-indemnity agreements. In 1960, CO notified N/A that it, N/A, would have to perform on its bond. Because the three corporations were close to insolvency, N/A asked COINC's stockholders to indemnify it. Only petitioner agreed to do so. As a part of the…

1Opinion of the Court

M. Seth Horne and Maurine D. Horne, Petitioners v. Commissioner of Internal Revenue, Respondent

Horne v. Commissioner

Docket No. 2645-70

United States Tax Court

59 T.C. 319; 1972 U.S. Tax Ct. LEXIS 18;

November 27, 1972, Filed

Decision will be entered under Rule 50.

Petitioner (husband) was a partner in a three-man firm. The three partners, as individuals, owned all the stock in COINC, which, in turn, owned all the stock in CORP and CO. All three corporations performed construction work. N/A, a bonding company, wrote bonds for all three corporations. All three corporations indemnified N/A on…

2Cases cited38 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
  3. Putnam v. CommissionerSupreme Court of the United States · 1956
  4. United States v. GeneresSupreme Court of the United States · 1972
  5. Arrowsmith v. CommissionerSupreme Court of the United States · 1952

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