Owen v. Commissioner
United States Tax Court
Petitioner, a Government employee living in Washington, D. C., from 1944 to 1954, maintained his law office in Grand Forks, North Dakota, during the years of his absence. During 1947, he performed no legal services in the office and he received no income other than his Government salary. Held, the expenses of maintaining the office during 1947 are not attributable to a trade or business carried on by petitioner.
1Opinion of the Court
OPINION.
FisheR, Judge:
Petitioner expended $1,615.88 during 1947 to maintain a law office in Grand Forks, North Dakota. He elected in his return for that year to take the standard deduction provided in section 23 (aa) of the 1939 Code, which election was irrevocably binding upon him. The standard deduction is in lieu of “all deductions other than those which under section 22 (n) are to be subtracted from gross income in computing adjusted gross income.” Section 23 (aa) (2) of the 1939 Code. Petitioner contends that the office expenses constitute deductions allowed by section 23 which are…
2Cases cited4 opinions
- Frank v. CommissionerUnited States Tax Court · 1953
- Hand v. CommissionerUnited States Tax Court · 1951
- Osborn v. CommissionerUnited States Tax Court · 1944
- Harris v. CommissionerUnited States Tax Court · 1954
3Cited by66 opinions
- Fischer v. CommissionerUnited States Tax Court · 1968
- Jackson v. CommissionerUnited States Tax Court · 1986
- Snow v. CommissionerUnited States Tax Court · 1958
- Koons v. CommissionerUnited States Tax Court · 1961
- Ford v. CommissionerUnited States Tax Court · 1971
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