James Donnelly v. Commissioner of Internal Revenue

WATERMAN, Circuit Judge.

Petitioner, a victim of infantile paralysis and abdominal cancer, seeks to reverse a Tax Court decision, 28 T.C. 1278, upholding a determination by the Commissioner of deficiencies in petitioner’s income taxes for the years 1953 and 1954. During those years petitioner, as a practical matter, could not use public transportation. He drove to and from his work as a buffer and polisher of rough plastics in a specially designed automobile owned by him. On his job he wore aprons and strong work clothes. On his 1953 and 1954 income tax returns the petitioner deducted the sums…