Legal Opinion

Starr v. Commissioner

United States Tax Court

Decided September 26, 1966No. Docket No. 342-65PublishedCited by 7 opinions

Petitioner, employed by the U.S. Steel Corp. at San Francisco, Calif., was permanently transferred at the sole behest of his employer to its new plant at Lander, Wyo. Held, the amount of the reimbursement received from his employer, for expenses incidental to petitioner's transfer, did not constitute taxable income to petitioner under section 61(a), I.R.C. 1954.

1Opinion of the Court

OPINION

Fat, Judge:

Respondent determined a deficiency in petitioners’ Federal income tax for the year 1962 in the 'amount of $185.48.

The issues presented for decision axe: (1) Whether the reimbursement received by Homer H. Starr (hereinafter referred to as petitioner) from his employer, for living expenses incurred subsequent to his arrival at his new post of duty, was includable in petitioner’s gross income under section 61 (a) of the Internal Revenue Code of 1954;1 and (2) if so, whether the various expenditures of petitioner were deductible as ordinary and necessary business expenses within…

Also in this document: Dissent.

2Cases cited12 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Knetsch v. United StatesSupreme Court of the United States · 1960
  3. Leo C. Cockrell, and Carol P. Cockrell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
  4. Cockrell v. CommissionerUnited States Tax Court · 1962
  5. Courtney v. CommissionerUnited States Tax Court · 1959

7 more not listed; retrieve them via the Exa API.

3Cited by7 opinions

  1. McLellan v. CommissionerUnited States Tax Court · 1968
  2. Lull v. CommissionerUnited States Tax Court · 1969
  3. Ashby v. CommissionerUnited States Tax Court · 1969
  4. Lull v. CommissionerUnited States Tax Court · 1969
  5. McLellan v. CommissionerUnited States Tax Court · 1968

2 more not listed; retrieve them via the Exa API.

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