Rambo v. Commissioner
United States Tax Court
T owned a vacation-type house in Montana, which he had at one time used with his family for recreation purposes. Upon his divorce in 1957 he began to use that house as his principal residence, from which he commuted to various jobs from 1957 through 1962. In 1961, T was hired by E Corp. and worked at a Montana jobsite to which he commuted from his house.
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T owned a vacation-type house in Montana, which he had at one time used with his family for recreation purposes. Upon his divorce in 1957 he began to use that house as his principal residence, from which he commuted to various jobs from 1957 through 1962. In 1961, T was hired by E Corp. and worked at a Montana jobsite to which he commuted from his house. In 1962, E Corp. assigned T to a temporary job outside Montana, and thereafter (for a number of years, including the tax years 1971 and 1972) T worked for E Corp. at a series of temporary jobs outside Montana. T continued to maintain his…
1Opinion of the Court
Raum, Judge:
The Commissioner determined the following deficiencies in petitioner’s individual Federal income tax:
Year Deficiency
1971 .$1,073.00
1972 .1,788.84
Both sides have made concessions, and the only issue for decision is whether petitioner is entitled to deductions in each of the 2 years for expenses for meals and lodging which he incurred while allegedly away from home in pursuit of his trade or business. See section 162(a)(2), I.R.C. 1954.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and accompanying exhibits are incorporated herein by this reference.
P…
2Cases cited12 opinions
- Kroll v. CommissionerUnited States Tax Court · 1968
- Tucker v. CommissionerUnited States Tax Court · 1971
- Michaels v. CommissionerUnited States Tax Court · 1969
- George Harvey James v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Jones v. CommissionerUnited States Tax Court · 1970
7 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Daly v. CommissionerUnited States Tax Court · 1979
- Barone v. CommissionerUnited States Tax Court · 1985
- Johnson v. CommissionerUnited States Tax Court · 2000
- Edwards v. CommissionerUnited States Tax Court · 1987
- Graboske v. CommissionerUnited States Tax Court · 1987
21 more not listed; retrieve them via the Exa API.