Chandler v. Commissioner
United States Tax Court
Deductions -- Travel Expenses -- Sec. 22 (n) (2), I. R. C., 1939. -- Petitioner was employed as high school principal by the City of Attleboro, Massachusetts, where he lived. He was also employed by Boston University at Boston, Massachusetts, 37 miles distant, two evenings a week as instructor. He used his personal automobile in traveling between the two cities.
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Deductions -- Travel Expenses -- Sec. 22 (n) (2), I. R. C., 1939. -- Petitioner was employed as high school principal by the City of Attleboro, Massachusetts, where he lived. He was also employed by Boston University at Boston, Massachusetts, 37 miles distant, two evenings a week as instructor. He used his personal automobile in traveling between the two cities. Held, the automobile expenses were not deductible because not incurred in connection with the performance of services by petitioner as an employee.
1Opinion of the Court
OPINION.
Tietjens, Judge:
All of the facts have been stipulated and we adopt the stipulation by reference.
Respondent determined a deficiency of $96.34 for the year 1950.
During 1950 petitioner was employed by the City of Attleboro, Massachusetts, as principal of its high school, at a salary of $5,480.
Also, during 1950 petitioner was employed by Boston University as a teacher of accounting in its night division in Boston, Massachusetts, for which he received $2,090.
Petitioner, who filed a joint return for 1950 with his wife with the collector of internal revenue for the district of Massachusetts,…
2Cases cited5 opinions
- Kershner v. CommissionerUnited States Tax Court · 1950
- Waters v. CommissionerUnited States Tax Court · 1949
- Smith v. CommissionerUnited States Tax Court · 1954
- Summerour v. AllenDistrict Court, M.D. Georgia · 1951
- Scott v. KelmDistrict Court, D. Minnesota · 1953
3Cited by14 opinions
- Freedman v. CommissionerUnited States Tax Court · 1961
- Deason v. CommissionerUnited States Tax Court · 1964
- Bagley v. CommissionerUnited States Tax Court · 1966
- Puckett v. CommissionerUnited States Tax Court · 1971
- Lopkoff v. CommissionerUnited States Tax Court · 1982
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