Greer v. Commissioner
United States Tax Court
Held, amounts expended by Greer's employer on behalf of Mrs. Greer for the purpose of transporting her in the corporate airplane are excluded from petitioners' gross income by sec. 105. Held, further, for the purposes of sec. 1251Greer was engaged in the trade or business of farming during the taxable years in issue.
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Held, amounts expended by Greer's employer on behalf of Mrs. Greer for the purpose of transporting her in the corporate airplane are excluded from petitioners' gross income by sec. 105. Held, further, for the purposes of sec. 1251Greer was engaged in the trade or business of farming during the taxable years in issue. Held, further, Greer completed his gift of J. Gould bird prints to the University of Tennessee on Dec. 22, 1972. Held, further, the cost of renting an apartment in Florida for the winter is not deductible under sec. 213.
1Opinion of the Court
Sterrett, Judge:
Respondent determined a deficiency in petitioners’ Federal income taxes for the calendar years 1970, 1971, and 1972 as follows:
Year Deficiency
1970 .$2,977.68
1971 .58,654.92
1972 ..28,691.62
90,324.22
After concessions by the parties the following issues remain for our determination: (1) Whether petitioners’ use of the corporate aircraft during these years resulted in taxable income to them calculated at the hourly rental value or was excludable from gross income under section 105(b), I.R.C. 1954; (2) whether John L. Greer, for purposes of section 1251(e)(4), was engaged in the…
2Cases cited5 opinions
- Commissioner v. BilderSupreme Court of the United States · 1962
- Daniel S. W. Kelly and Constance L. Kelly v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
- Pamplin v. SatterfieldTennessee Supreme Court · 1954
- Gamble v. CommissionerUnited States Tax Court · 1977
- Ray v. Leader Federal Savings & Loan AssociationCourt of Appeals of Tennessee · 1953
3Cited by17 opinions
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- Hearst Corp. v. United StatesUnited States Court of Federal Claims · 1993
- Kaufman v. CommissionerUnited States Tax Court · 1987
- Miller v. CommissionerUnited States Tax Court · 1991
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