Legal Opinion

Powell v. Commissioner

United States Board of Tax Appeals

Decided June 3, 1936No. Docket No. 73763PublishedCited by 23 opinions

1. The petitioner was earning salaries and other income for services performed in New York, while his home and principal place of business was in Boston. Held, he is entitled to deduct the amount which he expended in traveling, for food and lodging, and for other necessary purposes while away from home. 2. The petitioner, an individual, was also the sole trustee of a trust over which he had broad powers.

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1. The petitioner was earning salaries and other income for services performed in New York, while his home and principal place of business was in Boston. Held, he is entitled to deduct the amount which he expended in traveling, for food and lodging, and for other necessary purposes while away from home. 2. The petitioner, an individual, was also the sole trustee of a trust over which he had broad powers. He sold securities at market as an individual and made corresponding purchases for the trust. Shortly after 30 days had elapsed, he acquired a like amount of the same securities as an…

1Opinion of the Court

*658OPINION.

Murdook:

The petitioner lived near and conducted his principal business activities in Boston during 1930. He also spent about three days of each week in New York, where he managed two corporations and was also active in trying to arrange a consolidation involving one of the companies. He received a salary of $20,833.30 from one of the corporations during 1930 and he also received a small amount for his services to the other. He attended directors’ meetings in New York and elsewhere during 1930. Most of the expenditures in controversy were made for railroad fare to and from New York and…

2Cited by23 opinions

  1. Barnhill v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1945
  2. Perry v. CommissionerUnited States Tax Court · 1970
  3. Wallace v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1944
  4. Douglas A. Chandler v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1955
  5. Sapson v. Comm'rUnited States Tax Court · 1968

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