Handfield v. Commissioner
United States Tax Court
Petitioner, a Canadian, manufactured postal cards in Canada which were sold in the United States through an agreement with a news company. Held, under the agreement, the news company was the petitioner's agent for distributing the cards in the United States. Thus, petitioner was engaged in business within the United States and income from sales in this country is subject to income taxes.
1Opinion of the Court
OPINION.
Aeundell, Judge:
The principal question in this proceeding is whether the petitioner, a nonresident Canadian, was engaged in business in the United States during the year in controversy. The determination of this question depends upon the nature of the arrangement which the petitioner had for selling in this country an item which he manufactured in Canada.
The petitioner manufactures a novelty item called Folkards which is a kind of postal card. He had a contract with the American News Company by which the latter distributed his cards to newsstands in the United States where they were…
2Cases cited5 opinions
- Ludvigh v. American Woolen Co. of NYSupreme Court of the United States · 1913
- McCallum v. Bray-Robinson Clothing Co.Court of Appeals for the Sixth Circuit · 1928
- Edgewood Shoe Factories, Division of General Shoe Corp. v. StewartCourt of Appeals for the Fifth Circuit · 1939
- In Re TaylorDistrict Court, E.D. Michigan · 1931
- Ross v. H. Michaelyan, Inc.Court of Appeals for the Second Circuit · 1932
3Cited by9 opinions
- Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
- Zaffaroni v. CommissionerUnited States Tax Court · 1976
- Rosenkranz v. CommissionerUnited States Tax Court · 1976
- Challenge Publications, Inc. v. CommissionerUnited States Tax Court · 1986
- Allen v. CommissionerUnited States Tax Court · 1979
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