Heineman v. Commissioner
United States Tax Court
P, the chief executive officer of a large corporation, had his principal office in Chicago, Ill. He spent August reviewing the long-range plans of the corporation, and he could perform that work more effectively away from his Chicago office. He preferred to be away from Chicago in the summer, and in August, he lived in a summer home in Wisconsin.
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P, the chief executive officer of a large corporation, had his principal office in Chicago, Ill. He spent August reviewing the long-range plans of the corporation, and he could perform that work more effectively away from his Chicago office. He preferred to be away from Chicago in the summer, and in August, he lived in a summer home in Wisconsin. He erected and maintained a separate office on the property of his summer home, and he used such office exclusively for the review of the long-range corporate plans and the performance of other corporate work while he was in Wisconsin. Held, the…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined the following deficiencies in the petitioners’ Federal income taxes:
Year Deficiency
1976. $11,076.76
1977. 10,515.89
1978. 11,694.07
The issue for decision is whether the petitioners may deduct amounts attributable to the maintenance and depreciation of a separate office located on property where they also had a summer home under sections 162(a) and 167 of the Internal Revenue Code of 1954,1 or whether they are nondeductible personal expenses under section 262.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found.
The…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Commissioner v. TellierSupreme Court of the United States · 1966
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Lilly v. CommissionerSupreme Court of the United States · 1952
8 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- Gantner v. CommissionerUnited States Tax Court · 1988
- Noyce v. CommissionerUnited States Tax Court · 1991
- Feldman v. CommissionerUnited States Tax Court · 1985
- Ireland v. CommissionerUnited States Tax Court · 1987
- Griffiths v. United StatesUnited States Court of Federal Claims · 2002
32 more not listed; retrieve them via the Exa API.