HORNUNG V. COMMISSIONER
47 T.C. 428 (1967)
NATURE OF THE CASE: This was a dispute over the tax liability on a prize award. Hornung
(D) challenged the finding of a deficiency in his income tax payment for the taxable year
1962.
FACTS: D was a cash basis taxpayer who resided in Kentucky. D was employed by the Green
Bay Packers. D won the Sports Magazine award for the most outstanding player in the NFL
championship game of December 31, 1961. D got a Corvette but when the award was announced at
the end of the game D merely accepted the award but did not demand immediate possession of
the car. D was also told that a luncheon was to be held for him in New York City the
following Wednesday and the award would be presented. The car was presented on January 3,
1962. The fair market value of the car was $3,331.04. D reported the sale in 1962 but did
not include the market value of the car in his gross income for 1962. There were a number of
issues in the case but the only one portrayed in the casebook was the issue of receipt of
the property.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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