Kroll v. Commissioner
United States Tax Court
Petitioner, a child actor, and his mother lived in New York City during 1963, where petitioner appeared in two plays. During 1963 he attended private schools which provided him a regular grammar school curriculum but which were better suited for working children, such as the petitioner, than were the public schools.
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Petitioner, a child actor, and his mother lived in New York City during 1963, where petitioner appeared in two plays. During 1963 he attended private schools which provided him a regular grammar school curriculum but which were better suited for working children, such as the petitioner, than were the public schools. Held: 1. Petitioner's expenses for food and lodging in New York City in 1963 were not deductible traveling expenses, because he was not "away from home." 2. Petitioner's expenditures in 1963 for tuition were nondeductible personal expenses. 3. The food and lodging expenses of…
1Opinion of the Court
OPINION
Each of the issues in this case involves the deductibility of certain claimed expenses. The parties appear to assume, and we agree, that should any of the expenses in question be business expenses attributable to the petitioner’s income, the fact that payment of these expenses was made by his parents rather than by him will not prevent them from being deductible from the petitioner’s gross income. See sec. 73.
The first issue concerns the deductibility of meal and lodging expenses incurred by title petitioner while he lived in New York City in 1963. The record does not indicate what…
2Cases cited28 opinions
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- McDonald v. CommissionerSupreme Court of the United States · 1944
- Commissioner of Internal Revenue v. James E. Peurifoy, Paul v. Stines and Betty O. Stines, John S. Hall and Doris D. HallCourt of Appeals for the Fourth Circuit · 1958
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Schurer v. CommissionerUnited States Tax Court · 1944
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3Cited by356 opinions
- Tucker v. CommissionerUnited States Tax Court · 1971
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- Norwood v. CommissionerUnited States Tax Court · 1976
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