Curphey v. Commissioner
United States Tax Court
Petitioner, a dermatologist employed by a hospital, also owned and managed six rental properties. Held, his rental activities constituted a business for the purpose of sec. 280A, I.R.C. 1954. Held, further, petitioner was entitled to deduct expenses incurred for the use of a room in his residence, exclusively and on a regular basis, as an office in connection with his rental business, where such home office was the principal place at which he carried on that business.
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Petitioner, a dermatologist employed by a hospital, also owned and managed six rental properties. Held, his rental activities constituted a business for the purpose of sec. 280A, I.R.C. 1954. Held, further, petitioner was entitled to deduct expenses incurred for the use of a room in his residence, exclusively and on a regular basis, as an office in connection with his rental business, where such home office was the principal place at which he carried on that business. Sec. 280A(c)(1)(A), I.R.C. 1954. Held, further, costs of local transportation between such office in residence and…
1Opinion of the Court
Edwin R. Curphey, Petitioner v. Commissioner of Internal Revenue, Respondent
Curphey v. Commissioner
Docket No. 10546-78
United States Tax Court
73 T.C. 766; 1980 U.S. Tax Ct. LEXIS 195;
February 4, 1980, Filed
Decision will be entered under Rule 155.
Petitioner, a dermatologist employed by a hospital, also owned and managed six rental properties. Held, his rental activities constituted a business for the purpose of sec. 280A, I.R.C. 1954. Held, further, petitioner was entitled to deduct expenses incurred for the use of a room in his residence, exclusively and on a regular basis, as an office in…
2Cases cited37 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Higgins v. CommissionerSupreme Court of the United States · 1941
- United States v. GilmoreSupreme Court of the United States · 1963
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
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