Cullinan v. Commissioner
United States Board of Tax Appeals
1. The petitioner kept no itemized account of traveling expenses paid, but the amounts spent by him were in excess of the amounts repaid to him for traveling expenses. Held, that the petitioner derived no income from the repayments. 2. The petitioner acquired land and platted it into twenty-four lots.
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1. The petitioner kept no itemized account of traveling expenses paid, but the amounts spent by him were in excess of the amounts repaid to him for traveling expenses. Held, that the petitioner derived no income from the repayments. 2. The petitioner acquired land and platted it into twenty-four lots. He gave away one lot, kept three for himself and sold seventeen in 1919, one in 1920, one in 1921, and one in 1922, one-fifth of the sale price being received in cash and vendor's lien notes being given for the balance. The Commissioner apportioned the total cost of the land and improvements to…
1Opinion of the Court
*999OPINION.
Smith:
In his income-tax returns for the years 1919, 1920, and 1921, the petitioner did not include as income $9,000, $12,000, and $12,000, respectively, representing a partial reimbursement for expenses paid by him in connection with his duties as chief executive of two large corporations. Neither did he deduct from gross income any amount for expenses paid in connection with his activities as chief executive of the corporations. During the years in question he was continually engaged in rendering services to the corporations which, together with their respective subsidiaries, had…
2Cited by10 opinions
- Heiner v. MellonSupreme Court of the United States · 1938
- Hendrick v. CommissionerUnited States Tax Court · 1961
- Biscayne Bay Islands Co. v. Commissioner (A)United States Board of Tax Appeals · 1931
- Bovard v. CommissionerUnited States Board of Tax Appeals · 1929
- Bowman v. CommissionerUnited States Tax Court · 1955
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