Legal Opinion

Norwood v. Commissioner

United States Tax Court

Decided June 15, 1976No. Docket No. 1058-75PublishedCited by 122 opinions

Petitioner belonged to a local union in Washington, D.C., and lived near Washington. Because of a shortage of work in the Washington area, he was sent by his union to a job in Lusby, Md. He continued to live at home and drove to and from Lusby each working day. His first job at Lusby lasted 5 months, after which he received additional assignments extending over a continuous period of more than 2 years before his employment terminated due to an injury.

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Petitioner belonged to a local union in Washington, D.C., and lived near Washington. Because of a shortage of work in the Washington area, he was sent by his union to a job in Lusby, Md. He continued to live at home and drove to and from Lusby each working day. His first job at Lusby lasted 5 months, after which he received additional assignments extending over a continuous period of more than 2 years before his employment terminated due to an injury. Respondent concedes that the cost of driving between petitioner's home and Lusby was deductible if petitioner's employment was temporary in…

1Opinion of the Court

Tannenwald, Judge:

Respondent determined deficiencies of $694.50 and $302 in petitioners’ Federal income taxes for the years 1972 and 1973, respectively. The only issue for decision is whether petitioners are entitled to deduct costs incurred by petitioner Lawrence W. Norwood in traveling between his residence and his place of employment each working day.

FINDINGS OF FACT

Some of the facts are stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by this reference.

Petitioners are husband and wife. They resided in Adelphi, Md., at the time…

2Cases cited18 opinions

  1. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  2. Kroll v. CommissionerUnited States Tax Court · 1968
  3. Tucker v. CommissionerUnited States Tax Court · 1971
  4. Commissioner of Internal Revenue v. James E. Peurifoy, Paul v. Stines and Betty O. Stines, John S. Hall and Doris D. HallCourt of Appeals for the Fourth Circuit · 1958
  5. Leo C. Cockrell, and Carol P. Cockrell v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963

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

3Cited by122 opinions

  1. McCallister v. CommissionerUnited States Tax Court · 1978
  2. Zimmerman v. CommissionerUnited States Tax Court · 1978
  3. A. J. Michel, Jr. And Raymonde A. Michel v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
  4. Walker v. CommissionerUnited States Tax Court · 1993
  5. James v. CommissionerUnited States Tax Court · 1980

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

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