Legal Opinion

Richard R. Sibla v. Commissioner of Internal Revenue, Robert E. Cooper v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided January 7, 1980No. 78-1295, 77-3815PublishedCited by 56 opinions

1Opinion of the Court

CURTIS, District Judge:

We have before us two appeals from decisions of the tax court upon nearly identical fact situations, the difference between them being of no relevance on this appeal. A single opinion therefore seems appropriate for the disposition of both.

These appeals involve an attempt by the taxpayers to deduct from their respective incomes their share of expenses of a mandatory organized mess at the firehouse where they were stationed. The tax court decided in favor of the taxpayers and the Commissioner has appealed.

The relevant facts are largely undisputed.

FACTS

During the relevant…

2Cases cited7 opinions

  1. Commissioner v. HeiningerSupreme Court of the United States · 1943
  2. Commissioner v. KowalskiSupreme Court of the United States · 1977
  3. George Harvey James v. United StatesCourt of Appeals for the Ninth Circuit · 1962
  4. Harry G. Laforge and Mildred E. Laforge v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
  5. Kowalski v. Comm'rUnited States Tax Court · 1975

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

3Cited by56 opinions

  1. Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  2. Elliotts, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  3. Vukasovich, Inc. v. Commissioner of Internal Revenue, Vukasovich, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
  4. Max Sobel Wholesale Liquors v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  5. John D. Moss, Jr. And Diane C. Moss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985

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

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