Legal Opinion

John Manocchio v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided July 19, 1983No. 82-7588PublishedCited by 81 opinions

1Opinion of the Court

NELSON, Circuit Judge:

Manocehio (taxpayer) appeals from the Tax Court’s decision to deny in part his deduction of the cost of a flight training course as a business expense. Ninety percent of the expense of the course had been reimbursed under a veterans’ benefit program. The Tax Court held that the reimbursed portion of the expense was not deductible, that a prior revenue ruling and I.R.S. publication to the contrary did not estop the I.R.S. from retroactively denying the deduction, and that the I.R.S.’s decision did not impermissibly single out veterans who received flight training…

2Cases cited17 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  4. Dixon v. United StatesSupreme Court of the United States · 1965
  5. Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976

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

3Cited by81 opinions

  1. Centex Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2005
  2. Preben Norgaard Sandra C. Norgaard v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1991
  3. Russell Redhouse, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
  4. Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
  5. Estate of Gardner v. CommissionerUnited States Tax Court · 1984

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

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