Phillips v. Commissioner
United States Tax Court
M, a firefighter, was required under a Union contract to eat his meals at the station house while on duty and to contribute to a Station Fund for the cost of the meals. Held, amounts contributed to the Station Fund are not deductible business expenses under section 162(a), I.R.C. 1954, or excludable as meals furnished for the convenience of M's employer under section 119, I.R.C. 1954. Sibla v. Commissioner,611 F.2d 1260 (9th Cir. 1980), affg.
Read the full summary
M, a firefighter, was required under a Union contract to eat his meals at the station house while on duty and to contribute to a Station Fund for the cost of the meals. Held, amounts contributed to the Station Fund are not deductible business expenses under section 162(a), I.R.C. 1954, or excludable as meals furnished for the convenience of M's employer under section 119, I.R.C. 1954. Sibla v. Commissioner,611 F.2d 1260 (9th Cir. 1980), affg. Sibla v. Commissioner,68 T.C. 422 (1977), and Cooper v. Commissioner,67 T.C. 870 (1977), distinguished. Held further, since the decision of the Ninth…
1Opinion of the Court
MICHAEL AND ALICE P. PHILLIPS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Phillips v. Commissioner
Docket No. 7627-85.
United States Tax Court
T.C. Memo 1986-503; 1986 Tax Ct. Memo LEXIS 104; 52 T.C.M. (CCH) 747; T.C.M. (RIA) 86503;
October 6, 1986; As Amended November 3, 1986
M, a firefighter, was required under a Union contract to eat his meals at the station house while on duty and to contribute to a Station Fund for the cost of the meals. Held, amounts contributed to the Station Fund are not deductible business expenses under section 162(a), I.R.C. 1954, or excludable as meals…
2Cases cited6 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sutter v. CommissionerUnited States Tax Court · 1953
- Richard R. Sibla v. Commissioner of Internal Revenue, Robert E. Cooper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Sibla v. CommissionerUnited States Tax Court · 1977
- Cooper v. CommissionerUnited States Tax Court · 1977
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- United States v. MusinDistrict Court, S.D. Iowa · 2011