Legal Opinion

Black v. Commissioner

United States Tax Court

Decided April 24, 1973No. Docket No. 3475-71Published

Petitioner was employed as a comptroller. Prior to the amendment of sec. 217, I.R.C. 1954, by the 1969 Tax Reform Act, petitioner was transferred from Tiffin, Ohio, to Philadelphia, Pa., by his employer.

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Petitioner was employed as a comptroller. Prior to the amendment of sec. 217, I.R.C. 1954, by the 1969 Tax Reform Act, petitioner was transferred from Tiffin, Ohio, to Philadelphia, Pa., by his employer. Petitioner sold his home in Tiffin and paid a real estate brokerage commission of $ 1,578. He purchased a new home in Pennsylvania and paid a Pennsylvania real estate transfer tax of $ 340. Petitioner also engaged the services of a job-counseling organization for a fee of $ 1,875 to assist him in obtaining a better job. Petitioner obtained new employment; however, the job-counseling…

1Opinion of the Court

Leonard C. Black and Dolores M. Black, Petitioners v. Commissioner of Internal Revenue, Respondent

Black v. Commissioner

Docket No. 3475-71

United States Tax Court

60 T.C. 108; 1973 U.S. Tax Ct. LEXIS 140; 60 T.C. No. 13;

April 24, 1973, Filed

Decision will be entered under Rule 50.

Petitioner was employed as a comptroller. Prior to the amendment of sec. 217, I.R.C. 1954, by the 1969 Tax Reform Act, petitioner was transferred from Tiffin, Ohio, to Philadelphia, Pa., by his employer. Petitioner sold his home in Tiffin and paid a real estate brokerage commission of $ 1,578. He purchased a new home in…

2Cases cited9 opinions

  1. United States v. GeneresSupreme Court of the United States · 1972
  2. McDonald v. CommissionerSupreme Court of the United States · 1944
  3. Cremona v. CommissionerUnited States Tax Court · 1972
  4. Carey v. CommissionerUnited States Tax Court · 1971
  5. Giffin v. CommissionerUnited States Board of Tax Appeals · 1930

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