Jenkins v. Commissioner
United States Tax Court
Held: Per diem and mileage allowances received by petitioner Charles J. Jenkins while performing services for the Brotherhood of Railroad Trainmen are includable in gross income. Held, further: Petitioner's home for deductibility of expenses while traveling away from home purposes was Springfield, Illinois, since this was the location of his substantial and indefinite employment. Allowable deductions from the per diem and mileage allowances determined.
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Held: Per diem and mileage allowances received by petitioner Charles J. Jenkins while performing services for the Brotherhood of Railroad Trainmen are includable in gross income. Held, further: Petitioner's home for deductibility of expenses while traveling away from home purposes was Springfield, Illinois, since this was the location of his substantial and indefinite employment. Allowable deductions from the per diem and mileage allowances determined. Held, further: No part of the underpayment was attributable to negligence or intentional disregard of the rules and regulations within the…
1Opinion of the Court
Charles J. Jenkins and Anna V. Jenkins v. Commissioner.
Jenkins v. Commissioner
Docket No. 5096-64.
United States Tax Court
T.C. Memo 1967-257; 1967 Tax Ct. Memo LEXIS 5; 26 T.C.M. (CCH) 1328; T.C.M. (RIA) 67257;
December 27, 1967
Held: Per diem and mileage allowances received by petitioner Charles J. Jenkins while performing services for the Brotherhood of Railroad Trainmen are includable in gross income.
Held, further: Petitioner's home for deductibility of expenses while traveling away from home purposes was Springfield, Illinois, since this was the location of his substantial and indefinite…
2Cases cited13 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- 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
- Garlock v. CommissionerUnited States Tax Court · 1960
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Charles J. Jenkins and Anna v. Jenkins v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1969