Legal Opinion

Jones v. Comm'r

United States Tax Court

Decided February 9, 2016No. Docket No. 27187-12Published

Ps claimed above-the-line deductions under I.R.C. sec. 62 on their 2008, 2009, and 2010 tax returns for expenses related to H's position as a public official. R examined Ps' 2008, 2009, and 2010 returns and determined that while H was entitled to certain deductions for expenses, he could deduct them only as unreimbursed employee business expenses, which would not reduce Ps' tax liability.

Read the full summary

Ps claimed above-the-line deductions under I.R.C. sec. 62 on their 2008, 2009, and 2010 tax returns for expenses related to H's position as a public official. R examined Ps' 2008, 2009, and 2010 returns and determined that while H was entitled to certain deductions for expenses, he could deduct them only as unreimbursed employee business expenses, which would not reduce Ps' tax liability. R also determined that Ps were liable for accuracy-related penalties under I.R.C. sec. 6662(a). Held: Under I.R.C. sec. 62(a)(2)(C), a "fee based" public official is an official who receives fees directly…

1Opinion of the Court

MICHAEL JONES AND M. CHASTAIN JONES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Jones v. Comm'r

Docket No. 27187-12.

United States Tax Court

146 T.C. 39; 2016 U.S. Tax Ct. LEXIS 3; 146 T.C. No. 3;

February 9, 2016, Filed

Decision will be entered under Rule 155.

Ps claimed above-the-line deductions under I.R.C. sec. 62 on their 2008, 2009, and 2010 tax returns for expenses related to H's position as a public official. R examined Ps' 2008, 2009, and 2010 returns and determined that while H was entitled to certain deductions for expenses, he could deduct them only as unreimbursed…

2Cases cited13 opinions

  1. Skidmore v. Swift & Co.Supreme Court of the United States · 1944
  2. Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
  3. Davis v. Michigan Department of the TreasurySupreme Court of the United States · 1989
  4. Crane v. CommissionerSupreme Court of the United States · 1947
  5. Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API