Herbert G. Hatt v. Commissioner

Herbert G. Hatt (defendant) married Dorothy Echols, president and majority stockholder of Johann, a funeral home company; Echols then transferred majority ownership to Hatt and made him president and general manager. Hatt moved into an apartment in the same building as the funeral home, where an ambulance crew the funeral home oversaw also lived. After business hours, Hatt handled calls and met customers from his apartment, and evidence showed it was customary in the area for funeral homes to keep someone living on-site to accommodate customers around the clock.