Duggan v. Commissioner
United States Tax Court
Petitioner, a fireman, was required to eat his meals at the station house while on 24-hour duty. Held, amounts contributed for the purchase of groceries and utensils are not deductible business expenses under sec. 162(a). Sibla v. Commissioner, 68 T.C. 422 (1977), and Cooper v. Commissioner, 67 T.C. 870 (1977), both affd. Sibla v. Commissioner, 611 F.2d 1260 (9th Cir. 1980), distinguished.
1Opinion of the Court
Irwin, Judge:
Respondent initially determined a deficiency of $175 in petitioners’ Federal income tax for 1976. After certain concessions by petitioners and the assessment and payment of a portion of the deficiency, the issues remaining for decision are whether petitioner Thomas J. Duggan1 is entitled to a deduction under section 162(a)2 for expenses incurred for meals eaten while on duty as a firefighter and, if so, whether such expenses have been properly substantiated.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The stipulation of facts as amended at…
2Cases cited5 opinions
- Sutter v. CommissionerUnited States Tax Court · 1953
- Richard R. Sibla v. Commissioner of Internal Revenue, Robert E. Cooper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Sibla v. CommissionerUnited States Tax Court · 1977
- Osteen v. CommissionerUnited States Tax Court · 1950
- Cooper v. CommissionerUnited States Tax Court · 1977
3Cited by16 opinions
- Moss v. CommissionerUnited States Tax Court · 1983
- Christey v. United StatesCourt of Appeals for the Eighth Circuit · 1988
- Alvarado v. CommissionerUnited States Tax Court · 1985
- Phillips v. CommissionerUnited States Tax Court · 1986
- Russo v. CommissionerUnited States Tax Court · 1982
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