Hornung v. Commissioner
United States Tax Court
47 T.C. 428 (1967)
In 1961, Hornung (plaintiff) was a football player for the Green Bay Packers. On December 31, 1961, Hornung played in the National Football League (NFL) championship game in Green Bay, Wisconsin. After the game, Sport Magazine (Sport) named him the outstanding player of the game. Sport is a New York publication that annually awards a new Corvette to athletes for outstanding performance. Sport announced the award to Hornung immediately after the game. Hornung agreed to appear at a luncheon in New York City a few days later to officially accept the car. Sport did not make the car available to Hornung on the day of the game. Hornung did not receive a key or title to the car, and no arrangements were made for Hornung to receive the car prior to the luncheon. At the time, the car was held at a New York dealership that was closed the day of the game. Although in previous years, Sport made the car available for pick up in New York on the day of the game, Sport did not believe the winner of the car would choose to travel from Green Bay to New York City immediately after the game. On January 3, 1962, Hornung accepted the car in New York City. Hornung did not report the car as income in 1962 or any other year. The Commissioner (defendant) determined the value of the car should have been included in Hornung’s gross income for 1962.
Rule of Law
Holding and Reasoning (Hoyt, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 166,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.