Sharon v. Commissioner
United States Tax Court
1. P was an attorney employed by the IRS. During 1969 and 1970, he occasionally used one room in his apartment as a place for doing office work. Held, P is not entitled to deductions under sec. 162 or sec. 212, I.R.C. 1954, for one-sixth of the rental and other costs of the apartment.
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1. P was an attorney employed by the IRS. During 1969 and 1970, he occasionally used one room in his apartment as a place for doing office work. Held, P is not entitled to deductions under sec. 162 or sec. 212, I.R.C. 1954, for one-sixth of the rental and other costs of the apartment. Stephen A. Bodzin, 60 T.C. 820 (1973), revd. 509 F.2d 679 (4th Cir. 1975), cert. denied 423 U.S. 825 (1975), will no longer be followed. 2. To enable P to enter the legal profession, the following amounts were spent by or on his behalf: $ 11,125 to obtain a college degree; $ 6,910 to obtain a law school degree;…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal income tax in the amounts of $235.56 for 1969 and $653.70 for 1970. Due to concessions, the following issues remain for decision: (1) Whether one-sixth of the petitioners’ rental and other costs of the apartment is deductible under either section 162(a) or section 212 of the Internal Revenue Code of 19541 as the cost of maintaining an office in their home; (2) whether the petitioners are entitled to amortization deductions under section 167(a)(1) with respect to certain educational and other expenses incurred…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Primuth v. CommissionerUnited States Tax Court · 1970
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Fausner v. CommissionerSupreme Court of the United States · 1973
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3Cited by161 opinions
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Key Buick Co. v. CommissionerUnited States Tax Court · 1977
- McQuiston v. CommissionerUnited States Tax Court · 1982
- Gestrich v. CommissionerUnited States Tax Court · 1980
- Ernest Drucker, Patricia Rogers, Philip Cherry and Ruth Cherry, Petitioners v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1983
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