Bermingham v. Commissioner
United States Tax Court
Petitioners' 1987 dividend and capital gain distributions from a mutual fund were reinvested in the fund. At the end of 1987 petitioners' holdings in the fund were worth less than their original investment. Petitioners deducted lodging expenses for petitioner husband (H); expenses for H's tools and professional dues; clothes and grooming expenses for petitioner wife (W); and H's contribution to an individual retirement account.
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Petitioners' 1987 dividend and capital gain distributions from a mutual fund were reinvested in the fund. At the end of 1987 petitioners' holdings in the fund were worth less than their original investment. Petitioners deducted lodging expenses for petitioner husband (H); expenses for H's tools and professional dues; clothes and grooming expenses for petitioner wife (W); and H's contribution to an individual retirement account. During 1987 W was an active participant in her employer's tax-qualified employees plan. 1. Held: Petitioners' dividend and capital gain distributions were income in…
1Opinion of the Court
RAYMOND J. BERMINGHAM AND FELICIA A. BERMINGHAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Bermingham v. Commissioner
Docket No. 24897-90
United States Tax Court
T.C. Memo 1994-69; 1994 Tax Ct. Memo LEXIS 73; 67 T.C.M. (CCH) 2200;
February 23, 1994, Filed
Decision will be entered under Rule 155.
Petitioners' 1987 dividend and capital gain distributions from a mutual fund were reinvested in the fund. At the end of 1987 petitioners' holdings in the fund were worth less than their original investment. Petitioners deducted lodging expenses for petitioner husband (H); expenses for H's…
2Cases cited55 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Neely v. CommissionerUnited States Tax Court · 1985
- Commissioner v. FlowersSupreme Court of the United States · 1946
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