Hamblen v. Commissioner
United States Tax Court
P, a minister of the Calvary Bible Church, regularly performed some of his ministerial duties in an office in his home. In 1976, he made daily round trips by automobile from his home office to his church office, which was his principal place of work. He deducted the costs of such transportation as a business expense under sec. 162(a), I.R.C. 1954. Respondent disallowed the claimed deduction.
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P, a minister of the Calvary Bible Church, regularly performed some of his ministerial duties in an office in his home. In 1976, he made daily round trips by automobile from his home office to his church office, which was his principal place of work. He deducted the costs of such transportation as a business expense under sec. 162(a), I.R.C. 1954. Respondent disallowed the claimed deduction. Held, in these circumstances, such transportation costs constitute commuting expenses which are personal and nondeductible.
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency of $248.87 in petitioners’ Federal income tax for 1976.
Petitioners have not contested certain minor adjustments to medical expense and sales tax deductions and the earned income credit. The only issue presented for our decision is whether petitioner Frank R. Hamblen, a minister, is entitled to deduct under section 162(a)1 automobile expenses incurred in traveling to and from his home, where he had an office and performed ministerial duties, and his principal place of work at the Calvary Bible Church.
The facts have been stipulated by the…
2Cases cited12 opinions
- Fausner v. CommissionerSupreme Court of the United States · 1973
- William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- United States v. John Paul MalinowskiCourt of Appeals for the Third Circuit · 1973
- Curphey v. CommissionerUnited States Tax Court · 1980
- Green v. CommissionerUnited States Tax Court · 1972
7 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Lary v. United StatesDistrict Court, N.D. Alabama · 1985
- Rhoads v. CommissionerUnited States Tax Court · 1987
- Dudley v. CommissionerUnited States Tax Court · 1987
- Hamblen v. CommissionerUnited States Tax Court · 1982
- Kisicki v. CommissionerUnited States Tax Court · 1987