Legal Opinion

Bochner v. Commissioner

United States Tax Court

Decided February 22, 1977No. Docket No. 5900-74PublishedCited by 64 opinions

Petitioner's only connection with his alleged tax home in California was a leased apartment and a desire to return. Held, such contacts are insufficient to render California his tax home. Held, further, petitioner's claimed theft loss deduction is denied.

1Opinion of the Court

Sterrett, Judge:

Respondent determined a deficiency in petitioner’s Federal income tax for the calendar year 1971 in the amount of $1,952.61. The issues for decision are: (1) Whether petitioner’s tax home was Glendora, Calif., during the year at issue thereby entitling him to deduct travel and living expenses incurred in connection with temporary employment away from Glendora; (2) whether respondent has fairly raised the issue of substantiation of certain of the aforenoted expenditures and, if so, whether petitioner has substantiated said expenses; and (3) whether petitioner is entitled to a…

2Cases cited9 opinions

  1. Commissioner v. FlowersSupreme Court of the United States · 1946
  2. Peurifoy v. CommissionerSupreme Court of the United States · 1958
  3. Tucker v. CommissionerUnited States Tax Court · 1971
  4. 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
  5. Michaels v. CommissionerUnited States Tax Court · 1969

4 more not listed; retrieve them via the Exa API.

3Cited by64 opinions

  1. Boyer v. CommissionerUnited States Tax Court · 1977
  2. Rambo v. CommissionerUnited States Tax Court · 1978
  3. A. J. Michel, Jr. And Raymonde A. Michel v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
  4. Andrews v. CommissionerUnited States Tax Court · 1990
  5. Felber v. CommissionerUnited States Tax Court · 1992

59 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API