Michael A. Tougher, Jr., and Amelia L. Tougher v. Commissioner of Internal Revenue

In reporting income for the years 1963 and 1964, Taxpayers, Michael A. Tougher, Jr. and Amelia L. Tougher, his wife, deducted from gross income the cost of supplies—principally groceries—purchased by Mrs. Tougher for family use from the Federal Aviation Administration Commissary on Wake Island, where Mr. Tougher was then employed by the F.A.A. as an electronic technician.

The Commissioner disallowed these deductions and determined deficiencies in the Toughers’ income taxes resulting from these adjustments. The Tax Court, concluding that the deductions did not fall within the purview of Section…