Horne v. Commissioner
United States Tax Court
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.
Read the full summary
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Putnam v. CommissionerSupreme Court of the United States · 1956
- United States v. GeneresSupreme Court of the United States · 1972
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
33 more not listed; retrieve them via the Exa API.