Pollei v. Commissioner
United States Tax Court
Ps are police captains who receive a car allowance to operate specially equipped, personally owned vehicles in the performance as employees. Ps have deducted expenses of operation "against" the allowance. R has only questioned the portion of the deductions which are attributable to travel between police headquarters and Ps' homes.
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Ps are police captains who receive a car allowance to operate specially equipped, personally owned vehicles in the performance as employees. Ps have deducted expenses of operation "against" the allowance. R has only questioned the portion of the deductions which are attributable to travel between police headquarters and Ps' homes. Ps have attempted to distinquish their case from others where we have found travel to be commuting by pointing out the requirement to be in contact with headquarters by radios. R contends that Ps must be in radio contact during any use of the specially equipped…
1Opinion of the Court
GERBER, Judge:
Respondent determined 1981. Federal income tax deficiencies of $537.30 for petitioners Pollei and $442 for petitioners Patrick and their cases have been consolidated for purposes of trial, briefing, and opinion. The sole issue for our consideration is whether police officers aré entitled to deduct the cost of operating ah unmarked police department equipped vehicle between their residence and police headquarters.
FINDINGS OF FACT
All petitioners resided in Salt Lake City, Utah, at the time each of the petitions was filed. Petitioners Jon R. Pollei (Pollei) and Harry W. Patrick…
2Cases cited13 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Fausner v. CommissionerSupreme Court of the United States · 1973
- United States v. Lee W. Tauferner and Carolyn E. TaufernerCourt of Appeals for the Tenth Circuit · 1969
- Fausner v. CommissionerUnited States Tax Court · 1971
- Gilberg v. CommissionerUnited States Tax Court · 1971
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3Cited by5 opinions
- Pollei v. CommissionerUnited States Tax Court · 1990
- Jon R. And Carol J. Pollei, and Harry W. And Renee L. Patrick v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1989
- Freeman v. Comm'rUnited States Tax Court · 2009
- Pollei v. CommissionerUnited States Tax Court · 1990
- Pollei v. CommissionerUnited States Tax Court · 1986