Morgan v. Commissioner
United States Tax Court
Petitioner owned two automobiles, one of which was used primarily in petitioner's trade or business. Held, petitioner failed to prove that the business use of that automobile was in excess of the amount determined by respondent. Petitioner owned a yacht. Held further, petitioner failed to substantiate the business use of the yacht as required under sec. 274. The yacht was damaged during a hurricane.
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Petitioner owned two automobiles, one of which was used primarily in petitioner's trade or business. Held, petitioner failed to prove that the business use of that automobile was in excess of the amount determined by respondent. Petitioner owned a yacht. Held further, petitioner failed to substantiate the business use of the yacht as required under sec. 274. The yacht was damaged during a hurricane. Held further, all damages alleged by petitioner were covered by insurance with the exception of the $400 deductible clause. Therefore, petitioner is entitled to a sec. 165(c)(3) deduction only to…
1Opinion of the Court
F. TYLER MORGAN AND HELEN W. MORGAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Morgan v. Commissioner
Docket No. 4338-74
United States Tax Court
T.C. Memo 1978-116; 1978 Tax Ct. Memo LEXIS 394; 37 T.C.M. (CCH) 524; T.C.M. (RIA) 780116;
March 27, 1978.
Petitioner owned two automobiles, one of which was used primarily in petitioner's trade or business. Held, petitioner failed to prove that the business use of that automobile was in excess of the amount determined by respondent. Petitioner owned a yacht. Held further, petitioner failed to substantiate the business use of the yacht as…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- Marcello v. CommissionerUnited States Tax Court · 1964
- Axelrod v. CommissionerUnited States Tax Court · 1971
- Nicholls, North, Buse Co. v. CommissionerUnited States Tax Court · 1971
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