Robinson v. Commissioner
United States Tax Court
The expenses of operation of a lodge and guest ranch should be computed without eliminating portions of the cost of food, insurance, fuel, electricity, laundry, and telephone to represent the cost of meals and lodging furnished to an owner-operator of the lodge and ranch who lodged and ate therein not for his own personal convenience but because it was necessary in connection with the operation of the lodge and ranch.
1Opinion of the Court
Withey, Judge:
The respondent has determined a deficiency of $241.16 in the petitioners’ income tax for 1953. The only issue for decision is what portions, if any, of the deductions taken by petitioners in their income tax return for operating costs and expenses incurred in the operation of a lodge and guest ranch represented personal living expenses of the petitioners and therefore were not deductible.
FINDINGS OF FACT.
The petitioners, who are husband and wife, have their residence and place of business at R. D. No. 2, Stroudsburg, Pennsylvania. They filed their joint individual income tax…
Also in this document: Dissent.
2Cases cited5 opinions
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Commissioner of Internal Revenue v. Richard E. And Helen MoranCourt of Appeals for the Eighth Circuit · 1956
- Commissioner of Internal Revenue v. Everett and Mary C. DoakCourt of Appeals for the Fourth Circuit · 1956
- Papineau v. CommissionerUnited States Tax Court · 1951
- United States v. William T. Briggs and Myrtle BriggsCourt of Appeals for the Tenth Circuit · 1956
3Cited by3 opinions
- Commissioner of Internal Revenue v. Thomas Robinson and Elaine RobinsonCourt of Appeals for the Third Circuit · 1959
- Commissioner of Internal Revenue v. Thomas Robinson and Elaine RobinsonCourt of Appeals for the Third Circuit · 1959
- Robinson v. CommissionerUnited States Tax Court · 1958