Legal Opinion

Peurifoy v. Commissioner

United States Tax Court

Decided October 31, 1956No. Docket Nos. 55694, 56074, 56262PublishedCited by 63 opinions

Deductions -- Traveling Expenses. -- Held, that the evidence establishes that the employment of the petitioners away from the places of their established residences was temporary in character and that the costs of meals, lodging, and transportation constituted deductible traveling expenses while away from home. Secs. 22 (n) and 23 (a) (1) (A), I. R. C. 1939.

1Opinion of the Court

OPINION.

Atkins, Judge:

The question presented is whether the expenses incurred by the petitioners for meals and lodging while engaged in work at the duPont plant at Kinston, and the cost of returning therefrom, upon termination of their employment, to the places of their residence, constitute allowable deductions under the provisions of sections 22 (n) and 23 (a) (1) (A) of the Internal Revenue Code of 1939,1 or whether they are nondeductible personal, living, or family expenses within the meaning of section 24 (a) (1) .2

There remains no controversy as to the amounts of any of the…

2Cases cited7 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Schurer v. CommissionerUnited States Tax Court · 1944
  3. Barnhill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1945
  4. Bark v. CommissionerUnited States Tax Court · 1946
  5. Herman C. Ford and Nellie Ford v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1955

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

3Cited by63 opinions

  1. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  2. Kroll v. CommissionerUnited States Tax Court · 1968
  3. 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
  4. Foote v. CommissionerUnited States Tax Court · 1976
  5. Kermit L. Claunch and Willodean Claunch v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959

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

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