Edwards v. Commissioner
United States Tax Court
Petitioner, a radiation safety technician, maintained his residence in Bruceton, Tennessee, during 1980 and 1981 and claimed deductions for living and traveling expenses incurred at job sites located throughout the eastern United States. Petitioner did not include as income the auto, lodging and meal allowances paid to him by his employer.
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Petitioner, a radiation safety technician, maintained his residence in Bruceton, Tennessee, during 1980 and 1981 and claimed deductions for living and traveling expenses incurred at job sites located throughout the eastern United States. Petitioner did not include as income the auto, lodging and meal allowances paid to him by his employer. Held, petitioner may not deduct such expenses since he was not away from home within the meaning of sec. 162(a)(2), I.R.C. 1954. Held further, such allowances received from petitioner's employer are includable in petitioner's taxable income.
1Opinion of the Court
GARY ALLISON EDWARDS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Edwards v. Commissioner
Docket Nos. 10435-84; 20667-85.
United States Tax Court
T.C. Memo 1987-396; 1987 Tax Ct. Memo LEXIS 393; 54 T.C.M. (CCH) 115; T.C.M. (RIA) 87396;
August 11, 1987.
Petitioner, a radiation safety technician, maintained his residence in Bruceton, Tennessee, during 1980 and 1981 and claimed deductions for living and traveling expenses incurred at job sites located throughout the eastern United States. Petitioner did not include as income the auto, lodging and meal allowances paid to him by his…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Leo C. Cockrell, and Carol P. Cockrell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Mitchell v. CommissionerUnited States Tax Court · 1980
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