Strohmaier v. Commissioner
United States Tax Court
P was an independent agent for an insurance brokerage firm and a part-time minister. P was not provided an office by the insurance brokerage firm; he was not required to report to or visit the brokerage firm office, nor did he conduct any business there. P, as a minister, was not affiliated with any church. He served as chaplain for a mobile home community, where he performed religious services. Occasionally, P delivered sermons or taught at various churches.
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P was an independent agent for an insurance brokerage firm and a part-time minister. P was not provided an office by the insurance brokerage firm; he was not required to report to or visit the brokerage firm office, nor did he conduct any business there. P, as a minister, was not affiliated with any church. He served as chaplain for a mobile home community, where he performed religious services. Occasionally, P delivered sermons or taught at various churches. In neither activity did P receive or interview insurance customers or religious patrons at his residence, nor did he perform…
1Opinion of the Court
OPINION
Parr, Judge:
This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(3)1 and Rules 180, 181, and 182. The Court agrees with and adopts the Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Couvillion, Special Trial Judge:
Respondent determined deficiencies of $766 and $1,954 in petitioner’s Federal income taxes for the years 1993 and 1994, respectively.
The issues for decision are: (1) Whether petitioner is entitled to a home office deduction under section 280A(c) for the year 1994 in connection with his…
2Cases cited13 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- United States v. CorrellSupreme Court of the United States · 1967
- Fausner v. CommissionerSupreme Court of the United States · 1973
- Commissioner v. SolimanSupreme Court of the United States · 1993
- Heuer v. CommissionerUnited States Tax Court · 1959
8 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Hill v. Comm'rUnited States Tax Court · 2010
- Anna M. Armstrong v. CommissionerUnited States Tax Court · 2020
- Beale v. CommissionerUnited States Tax Court · 2000
- Boring v. Comm'rUnited States Tax Court · 2015
- Burski v. Comm'rUnited States Tax Court · 2007
17 more not listed; retrieve them via the Exa API.