Heuer v. Commissioner
United States Tax Court
The petitioner, a Mississippi River boat pilot, received his piloting assignments from the pilots' association to which he belonged and was subject to call at any time. He used his automobile in driving from his residence to points of assignment and return, as well as between assignments.
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The petitioner, a Mississippi River boat pilot, received his piloting assignments from the pilots' association to which he belonged and was subject to call at any time. He used his automobile in driving from his residence to points of assignment and return, as well as between assignments. Held, that the portion of car expense and depreciation attributable to travel from his residence to points of assignment and return constitute nondeductible commuting expenses, but that the portion attributable to traveling between assignments is deductible. Secs. 23(a)(1)(A) and 23(l), 1939 Code, and secs.…
1Opinion of the Court
Atkins, Judge:
Respondent determined deficiencies in income tax of petitioners for tbe years 1953 and 1954 in the respective amounts of $547.64 and $423.20, 'and for the year 1953 determined additions to tax under section 294(d) (1) (A) and section 294(d) (2) of the Internal Revenue Code of 1939, in the respective amounts of $184.32 and $122.88.
The issue presented is whether the petitioner, a ship pilot, is entitled to deduct as ordinary and necessary business expenses, pursuant to section 23(a) (1) (A) of the Internal Revenue Code of 1939 and section 162(a) (2) of the Internal Revenue Code of…
2Cases cited15 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Podems v. CommissionerUnited States Tax Court · 1955
- Fuller v. CommissionerUnited States Tax Court · 1953
- Bixler v. CommissionerUnited States Board of Tax Appeals · 1927
- Fred N. Acker v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1958
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3Cited by154 opinions
- William W. Steinhort and Mildred Steinhort v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1964
- Curphey v. CommissionerUnited States Tax Court · 1980
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- Feistman v. CommissionerUnited States Tax Court · 1974
- Hynes v. CommissionerUnited States Tax Court · 1980
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