Coerver v. Commissioner
United States Tax Court
Husband was employed in Wilmington, Delaware, where he maintained a residence, and his wife was employed in New York City, where she maintained an apartment.
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Husband was employed in Wilmington, Delaware, where he maintained a residence, and his wife was employed in New York City, where she maintained an apartment. They filed a joint income tax return for each of the years 1956 and 1957. Held: The expenditures of the wife in New York City for rent, food, electricity, and other miscellaneous items, as well as her expenditures for train travel between New York City and Wilmington, are not deductible as ordinary and necessary business expenses on the joint returns. Such expenditures are nondeductible personal or living expenses. Sec. 262, I.R.C. 1954.
1Opinion of the Court
OPINION.
Mulroney, Judge:
The respondent determined deficiencies in the petitioners’ income taz for the years 1956 and 1957 in the respective amounts of $951.11 and $1,097.61. The only issue is whether the petitioners are entitled to deductions for travel expenses in the years 1956 and 1957 in the amounts of $2,806.22 and $3,306.67, respectively.
All of the facts have been stipulated and they are hereby incorporated by this reference.
Robert A. Coerver and Margaret M. Coerver, husband and wife, are residents of Wilmington, Delaware. They filed joint income tax returns for the years 1956 and 1957…
2Cases cited6 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Kershner v. CommissionerUnited States Tax Court · 1950
- Taft v. HelveringSupreme Court of the United States · 1940
- Helvering v. JanneySupreme Court of the United States · 1940
- Sherman v. CommissionerUnited States Tax Court · 1951
1 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Kroll v. CommissionerUnited States Tax Court · 1968
- Tucker v. CommissionerUnited States Tax Court · 1971
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Cockrell v. CommissionerUnited States Tax Court · 1962
- Dolan v. CommissionerUnited States Tax Court · 1965
51 more not listed; retrieve them via the Exa API.