Foote v. Commissioner
United States Tax Court
H and W owned a ranch in Lockhart, Tex., which was operated by H. They spent most of their time in Austin, Tex., where W was employed.
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H and W owned a ranch in Lockhart, Tex., which was operated by H. They spent most of their time in Austin, Tex., where W was employed. Held: (1) W's expenses for lodging in Austin were not deductible traveling expenses because she was not "away from home" within the meaning of sec. 162(a)(2), I.R.C. 1954; (2) H's expenses for lodging in Austin were nondeductible personal expenses; and (3) H's expenses of traveling between Austin and the ranch were nondeductible commuting expenses.
1Opinion of the Court
Simpson, Judge:
The Commissioner determined a deficiency of $237.30 in the petitioners’ Federal income tax for 1972. One issue has been conceded; the issues remaining for decision are: (1) Whether the petitioners are entitled to deduct expenditures for lodging in Austin, Tex., as traveling expenses under section 162(a)(2) of the Internal Revenue Code of 1954;1 and (2) whether the petitioners may deduct automobile expenses incurred by the petitioner Lou Foote in traveling between Austin and the petitioners’ ranch in Lockhart, Tex., as trade or business expenses.
FINDINGS OF FACT
Some of the facts…
2Cases cited19 opinions
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Peurifoy v. CommissionerSupreme Court of the United States · 1958
- Kroll v. CommissionerUnited States Tax Court · 1968
- Tucker v. CommissionerUnited States Tax Court · 1971
- Fausner v. CommissionerSupreme Court of the United States · 1973
14 more not listed; retrieve them via the Exa API.
3Cited by58 opinions
- Mitchell v. CommissionerUnited States Tax Court · 1980
- Daly v. CommissionerUnited States Tax Court · 1979
- Boser v. CommissionerUnited States Tax Court · 1981
- Cobb v. CommissionerUnited States Tax Court · 1981
- Horton v. CommissionerUnited States Tax Court · 1986
53 more not listed; retrieve them via the Exa API.